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RIDDLE&CODE FinTech Solutions: RIDDLE&CODE Becomes One of the First Fintech Companies in Austria to Receive FMA Licence

(0) RIDDLE&CODE FinTech Solutions, an innovative European company empowering financial institutions to handle all aspects of digital asset management, has obtained a licence as a service provider for virtual/cryptographic tokens by the Austrian Financial Market Authority (FMA). RIDDLE&CODE FinTech Solutions is one of the first fintech companies in Austria to be registered with FMA. The company is devoted to promoting tokenization of industrial services, where regulatory requirements are still in development and challenging to meet. Following successful registration, RIDDLE&CODE and its Token Management Platform-which have already been fully audited and accepted by Switzerland s regulator FINMA-are now licenced to safeguard and issue payment and utility tokens.

At a glance: cryptoassets for investment and financing in Austria

Regulatory threshold What attributes do the regulators consider in determining whether a cryptoasset is subject to regulation under the laws in your jurisdiction? The Financial Market Authority (FMA) operates a ‘technology-neutral’ approach, meaning that products and services involving cryptoassets are subject to the same regulatory framework as traditional products and services. The underlying rationale is ‘same risk, same rules’. Whether and to what extent financial services regulation and securities laws apply depends primarily on the actual product features and business model. Business models involving cryptoassets may be subject to licensing requirements and are governed by: the Banking Act – for example, if funds are raised for investment into cryptoassets or in the case of dealing as principal or agent in cryptoassets that qualify as financial instruments under the Markets in Financial Instruments Directive (MiFID) II (2014/65/EU);

First-step analysis: cryptoasset trading in Austria

What rules and restrictions govern the exchange of fiat currency and cryptoassets? The Fifth EU Anti-Money Laundering Directive was recently transposed into Austrian law. The directive newly extends anti-money laundering (AML) and know-your-customer (KYC) diligence requirements to: providers engaged in exchange services between virtual currencies and fiat currencies (ie, cryptocurrency exchanges); and electronic wallet providers (ie, entities providing services to safeguard private cryptographic keys to hold, store and transfer virtual currencies on behalf of their customers).   Also, since January 2020, certain providers of services concerning cryptocurrencies are subject to the AML and KYC and customer due diligence requirements, reporting obligations and registration requirements with the Financial Market Authority (FMA). This affects providers offering one or more of the following services:

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