DISCLAIMER: The term “cryptolicense” is used in this text as notification about a virtual asset service provider (VASP). The use of the term “cryptolicense” is intended solely to simplify the text for the customers and visitors of the website.

Bosnia and Herzegovina, a country located in the south of Europe, is a developed and forward-looking country with a good business environment. The country is committed to international economic cooperation, trade and foreign investment, as demonstrated by numerous successful projects in diverse industries. IT and crypto sectors are of great interest, as they offer multiple benefits due to the favorable investment climate.

As of today, Bosnia and Herzegovina has not adopted any law specifically regulating cryptocurrencies. The most significant event was the recognition of virtual currencies at the legislative level in Republika Srpska, one of the two administrative units of Bosnia and Herzegovina, by amending the Law on the Securities Market, which entered into force on September 21, 2022.

However, in February 2024, Bosnia and Herzegovina adopted a new Law on prevention of money laundering and financing of terrorist activities (AML Law). The law meets the key recommendations of the Financial Action Task Force on Money Laundering (FATF). The key innovation of the AML law is that it defines the concept of “VASP” at the legislative level.

If you want to obtain a cryptolicense in Bosnia and Herzegovina without any hassle - Manimama is ready to provide you with professional support and full assistance at every stage of the process. Entrust your cryptolicense to the experts and start your journey in the crypto world today!

Bosnia and Herzegovina has not adopted any law specifically regulating virtual currencies

Key Numbers about Cryptolicense in Bosnia and Herzegovina

1

director for a crypto company

no

minimum share capital requirement for a VASP

1

local MLRO for a cryptolicense holder

no

specific crypto taxation in Bosnia and Herzegovina

KM 1,000

the amount in excess of which the cryptocurrency licensee must perform identification measures

up to 2 weeks

timeline for registration of the company, which will obtain the cryptolicense

Legal Opinion about Cryptolicense in Bosnia and Herzegovina

Ganna Voievodina

Manimama

CEO

"The cryptolicense in Bosnia and Herzegovina marks a progressive shift towards embracing digital currencies, positioning the country as a forward-thinking player in the global financial landscape. Manimama will help you to obtain this cryptolicense easily."

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Types of Activities with a License in Bosnia and Herzegovina

Exchange of virtual currencies for currency that is legal tender

holders of cryptolicense enable the conversion between virtual and fiat currencies, offering customers the flexibility to transact in multiple currencies.

Organization of a platform for trading virtual currencies

cryptolicense holders are authorized to organize and manage a sophisticated platform for trading virtual currencies.

Exchange of virtual currency for another virtual currency

holders of cryptolicense are authorized to facilitate the exchange of various virtual currencies, including utility tokens and coins, ensuring diversified trading options.

Custody and/or management of virtual currencies or instruments that allow for the control of virtual currencies (wallet depository service provider)

holders of cryptolicense, through custodial wallets, offer a secure means of storing virtual currencies on behalf of users, with operators having the ability to open wallets while maintaining control over private keys.

Transferring virtual currency, i.e. receiving and fulfilling virtual currency orders on behalf of third parties

cryptolicense holders are authorized to facilitate the secure transfer of cryptocurrencies from clients' wallets to designated third-party wallets, presenting an alternative to traditional fiat wire transfers.

Participation and provision of financial services in connection with the offer and/or sale of virtual currency by the issuer

cryptolicensees may engage in activities related to the provision of financial services for the issuance or sale of virtual assets by an issuer.

Benefits of Obtaining a Cryptolicense in Bosnia and Herzegovina

Market expansion opportunities:

A cryptolicense enables businesses to expand their services across Bosnia and Herzegovina, tapping into a growing market.
With legal backing, companies can also explore opportunities in neighboring regions, increasing their market reach.

Promoting innovation and development:

With a legal framework in place, businesses can focus on innovation and developing new products and services.
This environment encourages technological advancements, positioning Bosnia and Herzegovina as a hub for cryptocurrency innovation.

Appealing tax system:

Bosnia and Herzegovina is characterized by a very favorable tax policy - the income tax rate is only 10% and there is no tax on dividends.
This policy enables crypto companies to enjoy a minimal tax burden and provide clients with the most favorable conditions.

National law:

Bosnia and Herzegovina is outside the EU, which allows it to remain free from the more stringent requirements of the EU.
As a result, the country can provide an efficient operating environment for cryptocurrency companies without being subject to MiCA regulations.

European region:

The country is located on the border with several European countries and has a direct connection to the EU.
The country is tightly connected to Europe in the cryptocurrency market, which can provide additional advantages.

Brand reputation and credibility:

Obtaining a cryptolicense can significantly boost a company’s reputation and credibility in the market.
A reputable brand can attract more users, partners, and investors, creating a positive cycle of growth and trust.

Our Services

Popular package

Premium

Full list of necessary services to set up of the VASP with connection to KYC providers, C2B account for the crypto transactions

Company formation in Bosnia and Herzegovina
Corporate account
“White card” for the non-resident director
Search, integration, direct employment agreement for exclusive, local, experienced director and MLRO
Individual AML policies
Cryptolicense obtaining
Registered address for 1 year
Set of apostilled corporate documents
C2B account for crypto transactions
Legal opinion for your VASP business

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Advanced

Set up of company ready to start cryptocurrency operational activity

Company formation in Bosnia and Herzegovina
Corporate account
“White card” for the non-resident director
Search, integration, direct employment agreement for exclusive, local, experienced director and MLRO
Individual AML policies
Cryptolicense obtaining
Registered address for 1 year
Set of apostilled corporate documents

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Basic

Creating the company and registration of VASP

Company formation in Bosnia and Herzegovina
Corporate account
“White card” for the non-resident director
Standard AML policies
Cryptolicense obtaining
Registered address for 1 year

Order now

Our Experts in this Area

Ganna Voievodina

CEO, co-founder

Yurii Pavlii

Lawyer

Step by Step Description

Step 1. Initial setup
- Initiating a preliminary project assessment
- Preparation and filing of the package of documents
Step 2. Company registration
- Selection and verification of the company name
- Facilitating the notarial process for the company's official registration
- Preparation and submission of necessary forms and documents to the Commercial Register
- Payment of government fees
Step 3. Opening a bank account (simultaneously with Step 2)

Opening of a limited bank account for the shared capital deposit. It includes evaluation of the most suitable bank, preparation of documents required and further assistance
Step 4. MLRO appointment and and AML/CFT compliance
- Appointment of the local Money laundering reporting officer (MLRO) who will communicate with the Regulator, notify of suspicious transactions, respond to AML requests
- Preparation of AML/CFT documentation
Step 5. Applying for a cryptolicense

Notification of the Securities Commission (Komisija za vrijednosne papire FBiH) about the company, which will operate in the crypto area, and qualification it as a VASP

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Understanding the Legal Requirements in Bosnia and Herzegovina

There is no special cryptolicense in Bosnia and Herzegovina, but notification the Securities Commission is mandatory

There is no special license for cryptocurrencies in Bosnia and Herzegovina, but notification (registration) with the Securities Commission is mandatory, as well as compliance with anti-money laundering and other financial regulations.

Thus, pursuant to Article 5 of the AML law, the crypto companies are responsible for taking measures to detect and prevent legalization (laundering) of proceeds of crime and financing of terrorist activities. For instance:

conducting a money laundering and terrorist financing risk assessment
establishing policies, procedures, controls and processes
implementing enhanced measures for higher risk situations
Implementation of simplified measures for lower risk situations
customer identification and monitoring
providing the FIU with information on transactions, assets and individuals
ensuring regular training of employees
and other

And note that identification and monitoring measures must be carried out by a cryptolicense holder, when performing occasional transactions in an amount exceeding KM1,000 (approx. €510), regardless of whether it is one or more interconnected transactions.

Requirements for Obtaining a Cryptolicense in Bosnia and Herzegovina

The holder of cryptolicense is required to have the local MLRO

In order to obtain a cryptolicense the person need to meet such requirements as:

it is necessary to register a legal entity (for example, limited liability company (društvo sa ograničenom odgovornošću)) in Bosnia and Herzegovina, because acquisition of a license for a foreign company is currently out of reach
there is no minimum share capital requirement for a holder of the cryptolicense
opening a limited bank account for the shared capital deposit
the director must have a work permit or “white card” in Bosnia and Herzegovina
hiring a local MLRO for a VASP
a cryptolicense holder is required to have AML/KYC rules drawn up in accordance with the legislation and FATF recommendations
the company must be registered in such state authorities as Tax Authorities, the Statistical Bureau and the Securities and Exchange Commission, etc.

There are 2 options for the director:

“White card” obtaining for the designated person for position of director. Director must come to the country in order to get it. This only needs to be done once.
Search and employment of the local director, so physical presence of shareholders or designated person in the country is not mandatory.

Taxes in Bosnia and Herzegovina

For now, there are no specific crypto taxes in Bosnia and Herzegovina

Corporate income tax (CIT)

If to consider the tax treatment of cryptocurrencies as transactions with intangible assets in accordance with Article 4 of the Law on Income Tax, then a legal entity must pay CIT at the rate of 10%.

Personal income tax (PIT)

If to look at the income received by an individual - income taxpayer on the basis of activities related to cryptocurrencies, including mining, then the same person should be liable to pay income tax under the Income Tax Act. PIT is payable at a rate of 10%.

Value-added tax (VAT)

The standard VAT rate is 17%. The VAT regime is applied in the same way throughout Bosnia and Herzegovina. There is no reduced VAT rate in Bosnia and Herzegovina. Note that there are no specific VAT rates for crypto transactions.

In general, as of 2024, Bosnia and Herzegovina has not established a comprehensive legal framework specifically for the taxation of cryptocurrencies.

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Frequently Asked Questions

What is a cryptolicense?

A cryptolicense is an official authorization required for businesses to operate in the cryptocurrency sector, ensuring compliance with legal and regulatory standards.
What are the benefits of obtaining a cryptolicense?

Benefits include legal compliance, increased consumer confidence, access to financial services, attracting investment, and market expansion opportunities.
What is cryptolicense in Bosnia and Herzegovina?

Cryptolicense in Bosnia and Herzegovina is the similar to VASP authorization in Europe - a selected activity (to work with cryptocurrencies) in accordance with the state regulation.
Why choose a Bosnia and Herzegovina cryptocurrency license?

Because this jurisdiction has all the privileges of the European region, but at the same time lacks essential drawbacks (for example, such as MiCA requirements).
Who needs a cryptolicense in Bosnia and Herzegovina?

Any business involved in cryptocurrency activities, such as trading, exchanging, or managing digital assets, needs to obtain a cryptolicense.
How long does it take to obtain a cryptolicense?

The processing time can vary, but it typically takes several weeks from the submission of the application to the issuance of the license.
What happens if a business operates without a cryptolicense?

Operating without a license can result in legal penalties, fines, and potential shutdown of the business.
Are there any restrictions on the turnover of cryptocurrency or fiat money?

No, the legislation does not stipulate any restrictions on turnover.
How does a business ensure compliance with AML and CTF regulations?

Businesses must implement robust AML and CTF policies and report any suspicious activities to the relevant authorities.
Can a cryptolicense be revoked?

Yes, a license can be revoked if a business fails to comply with regulatory requirements or engages in illegal activities.
Is there a minimum capital requirement for obtaining a cryptolicense?

No, there is no minimum capital requirements for VASPs.
How does a business update its information with the regulatory authorities?

Businesses must notify the regulatory authorities of any significant changes, such as changes in ownership, business structure, or key personnel.
Is there a possibility of not getting a cryptolicense?

If all documents are properly completed and submitted, you will receive a cryptolicense. Our experts thoroughly follow all stages of the process.

Vadym Hrusha

Trustee Wallet, CEO

"Manimama OU provided invaluable assistance with all the necessary paperwork. Their experience and competence is impressive and I recommend them to anyone who needs legal support".