How to open your bank in Europe: choose a country for the residence "Polybius"
As you may already know, Polybius is a European project, but not yet a European bank. To get the right so called, we need to get the appropriate license in a European country.
We have already decided on our shortlist: these are Lithuania, Luxembourg, Finland and Switzerland, but the most interesting is still to come. How to choose a country in which there will be our office, in which there will be our core of employees, in which we will pay taxes and to the regulators of which we report - our today's, slightly ethnographic post.
The license of the financial institution “Polybius” will receive after the ICO, because there are several types of such licenses, and only after the results of the public placement of our tokens will it be clear which of them we are applying for, as a result, an application.
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Actually, the ICO results will be the final factor in the choice of the country of incorporation of the Polybius Bank project. We can say it will be the results of our Oscar, when we announce who won. In the meantime, let us tell you what exactly these countries deserve their nominations, and the reader himself will be able to decide who has the chances of winning.
The list of criteria by which we will decide, we have reduced to the following four points:
Consider them in order.
Since this was the primary selection criterion, then, of course, both Lithuania, Luxembourg, and Finland, and Switzerland, pass on it without question - it was, in fact, they were chosen.
We wrote about the fintek-orientation of Lithuania in our blog before. Like another small Baltic country, Estonia, having gained independence 26 years ago, Lithuania found itself in a big and interesting world, where you have to achieve everything yourself. But if the Estonians decided that their topic in the international division of labor would be the construction of an e-state - perhaps the most advanced at the moment, the Lithuanians decided to occupy a niche in the fintek-friendly territory. And they are doing quite well so far: we are familiar with the Lithuanian Central Bank directly, through HashCoins, who planned and discussed with them a number of joint projects on the blockchain - that's why we seriously consider Lithuania as one of the main options for incorporating Polybius.
Switzerland's ambitions are even more serious: the country of the clock and the most satisfied alpine cows in the world do not rest on the laurels of the most respectable banking business of the planet, but seeks to keep up with the times and claims to be a technological hub for fintek startups. You know about it if you heard about the “ cryptodoline in the canton of Zug ” - a non-profit association lobbying for the interests of crypto -business and blockchain projects. Today, such cryptomir giants as Ethereum and Xapo are based in the canton of Zug. Every week or two, Swiss Crypto Vally conduct mitapes and hackathons, in some of which we have already participated as representatives of Polybius. And if we decide to stay in Switzerland officially, it is in the canton of Zug.
There we met with the law firm Wenger and Vieli, working with fintek and cryptodol in the canton of Zug. They regularly and densely communicate with the local regulator and share with us the most recent data. Including, for example, this review of the state of regulation, which notes that Switzerland is one of the first countries that, at the regulator level, approved the use of the blockchain at a financial institution, provided that the auditor confirms its operational safety. This is exactly what we are going to do in Polybius: transactions inside the bank on a closed blockchain, and security and document circulation on Emercoin.
It is even more convenient to communicate with regulators through law firms than directly. On the one hand, it is faster than trying to go through some official channels "from the street", on the other - quite reliably, because in the future cooperation will still be conducted with the participation of the same lawyers: they will apply for licenses, and accompany the bank in the future.
Luxembourg is not only one of the banking centers of Europe. Their loyalty to Fintek is evidenced by the fact that as early as 2007, when Paypal needed a banking license in the EU, they received it in Luxembourg - there is an old friendship between the local regulator and Fintec. And what's good for Paypal shouldn't be bad for Polybius either.
In Luxembourg, there is one of the offices of the law firm Hogan Lovells, which is working to ensure that our ICO complies with US law. In order for the Polybius token to trade on American cryptobirds, it is necessary that the conditions of ICO do not contradict the American securities law. And lawyers at Hogan Lovells check the placement structure, documentation, and even the code of a smart contract for compliance with US laws. Their main task is to register disclaimers in such a way that the placement conditions do not fall under the definition of an IPO at all. For Hogan Lovells, this is not the first such project: in their portfolio there are examples of other successful ICO on American exchanges. And, most likely, we will cooperate with them if we dwell on Luxembourg as the country of incorporation of Polybius.
Another feature of Luxembourg is the presence of a separate regulator. In Switzerland, the financial markets regulator is the FINMA Financial Market Supervision Authority of Switzerland, in Finland this is done by the Financial Supervision Authority FIN-FSA, and in Luxembourg the Financial Sector Supervision Commission (fr. Commission de Surveillance du Secteur Financier, CSSF) . In Lithuania, financial supervision functions are fully included in the authority of the Central Bank.
From our point of view, the separation of the financial regulator and the Central Bank indicates a more developed financial market. The task of the Central Bank is to monitor the monetary system (control inflation, lending rates within reasonable limits), and the regulator looks at the general behavior of financial institutions. This requires different expertise - in the Central Banks, experts in macroeconomics are primarily engaged, and for the regulator it is most important to understand the structure of financial markets. These are adjacent areas, but still require a different set of knowledge.
Moreover, the separation of these functions reduces the state’s pressure on the economy: for example, if the Central Bank, for example, Russia, which also does not have a separate regulator of financial markets, wants to raise the lending rate, then, controlling banks, it can simply put pressure on them. In countries with the separation of these functions, the regulator is more likely to be on the side of banks, allowing you to organize a more economically balanced solution.
We are familiar with the Finnish Central Bank and communicate through our strategic advisor Hugo Bekis. Hugo is a distinguished financier who has built his career in a number of major banks, including Deutsche Bank and Bank of America, a member of the European Cybercrime Task Force. Through his contact with the Central Bank, we are planning to meet and establish business relations with FIN-FSA.
There are so few projects like us, and each case is unique. Therefore, when we reduce our list to at least two countries, we’ll go talk to the representatives of the licensing departments of the financial institutions of these countries personally, get to know them, introduce ourselves - and make the final decision.
Very simple, but very important parameter. In many European countries, a progressive income tax scale is used (more income - higher tax) for individuals. Say, Finland is famous for perhaps the highest taxes on millionaires and billionaires in the world, but at the same time, the scale of tax on legal entities' income there is flat, although quite high: 20%. In Lithuania, the scale is also flat - and the tax is 14.5%, in Luxembourg - a progressive tax from 15% to 29% depending on the size of the company, and in Switzerland - 14% for all.
Since the main (and, possibly, the only) office of Polybius will be opened in the country of incorporation, we need countries with sufficiently qualified labor force. In Switzerland and Luxembourg, this is easiest because both countries have a long banking tradition and a good economic education. In Lithuania and Finland, educational institutions for the production of the specialists we need are much less sharpened. At the same time, Switzerland is the most expensive country in terms of labor force. For the salary of one employee in Switzerland, you can hire, roughly speaking, three in Lithuania. Luxembourg and Finland are here - something like a golden mean, while Luxembourg stands out due to the quality of financial education.
Again, only on the basis of ICO and the type of license of a financial institution that we receive will the final set of financial services with which we start, and which categories of specialists we will need - and which ones we will need in the office, and what tasks we can outsource.
For example, it is already clear that everything related to security and banking transactions, including development, should be under our supervision. And support may be able to work remotely. At the same time, it is difficult to single out a separate EU country in which there would be an increased concentration of IT specialists, which means we will have to “import” them anyway. And to convince to move to Switzerland or Luxembourg, especially in the early stages of our business, will be much easier because of the quality of life. And in Switzerland, moreover, simplified obtaining a residence permit for qualified IT specialists is being discussed .
Therefore, if you have experience and knowledge in the areas of banking, financial institutions, legislation or blockchain technologies, you can contact us by mail at support@polybius.io and get into the Polybius team now.
Only three countries from our list are members of the European Union (Switzerland, traditionally, is neutral), but even within the EU, countries have different policies and views of regulators on the fintech industry and crypto-projects.
A company licensed by one of the EU regulators (Lithuania, Luxembourg, Finland) automatically gets access to all European markets at once. Some products may still require additional licensing - for example, p2p lending in Germany requires a local license, but with a basic European one, this is a minor problem. In Switzerland, we get only a local license. And in the case of the same p2p-loans, we will need to obtain licenses already in each country of the European Union.
Other things being equal, each country is distinguished by something special. Switzerland is expensive, but it’s profitable in terms of reputation: the Swiss bank sounds solid. In Lithuania - cheap labor. In Finland, the most potentially friendly regulator. Luxembourg takes a combination of factors: not as expensive as Switzerland, but at the same level of financial development and advancement.
During ICO, Polybius tokens will be sold for $ 10 apiece with bonuses for earlier participation in the placement. These tokens will be distributed annually as a dividend of 20% of the annual, confirmed by European regulators of bank profits.
ICO "Polybius" until the end of spring. The exact date will be announced soon. In order not to miss this event, and to have time to purchase tokens in the first weeks, while there will be bonuses, subscribe to the newsletter with a notification on the website polybius.io .
We have already decided on our shortlist: these are Lithuania, Luxembourg, Finland and Switzerland, but the most interesting is still to come. How to choose a country in which there will be our office, in which there will be our core of employees, in which we will pay taxes and to the regulators of which we report - our today's, slightly ethnographic post.
How to start
The license of the financial institution “Polybius” will receive after the ICO, because there are several types of such licenses, and only after the results of the public placement of our tokens will it be clear which of them we are applying for, as a result, an application.
')
Lyrical digression: ICO - Initial Coin Offering, a cryptocurrency equivalent of an IPO (share placement). This is a crowdfunding campaign using cryptocurrency, usually organized by crypto-start or blockchain projects. The goal of ICO Polybius will be to raise funds for the launch of a cryptobank for all categories of the population and business. ICO "Polybius" starts until the end of spring 2017 and will last five weeks. The goal of the campaign is to collect from $ 1.5 million to $ 25 million to launch the bank and additional projects listed in the Polybius roadmap . ICO participants will be able to buy investment tokens for cryptocurrency or ordinary money, guaranteeing them a proportional share in the profits of the Polybius Bank project.
Actually, the ICO results will be the final factor in the choice of the country of incorporation of the Polybius Bank project. We can say it will be the results of our Oscar, when we announce who won. In the meantime, let us tell you what exactly these countries deserve their nominations, and the reader himself will be able to decide who has the chances of winning.
The list of criteria by which we will decide, we have reduced to the following four points:
- Loyalty to cryptostates, loyalty to Fintek
- Tax rate
- Staff availability
- Market access
Consider them in order.
Loyalty to Fintek and crypto projects
Since this was the primary selection criterion, then, of course, both Lithuania, Luxembourg, and Finland, and Switzerland, pass on it without question - it was, in fact, they were chosen.
We wrote about the fintek-orientation of Lithuania in our blog before. Like another small Baltic country, Estonia, having gained independence 26 years ago, Lithuania found itself in a big and interesting world, where you have to achieve everything yourself. But if the Estonians decided that their topic in the international division of labor would be the construction of an e-state - perhaps the most advanced at the moment, the Lithuanians decided to occupy a niche in the fintek-friendly territory. And they are doing quite well so far: we are familiar with the Lithuanian Central Bank directly, through HashCoins, who planned and discussed with them a number of joint projects on the blockchain - that's why we seriously consider Lithuania as one of the main options for incorporating Polybius.
Switzerland's ambitions are even more serious: the country of the clock and the most satisfied alpine cows in the world do not rest on the laurels of the most respectable banking business of the planet, but seeks to keep up with the times and claims to be a technological hub for fintek startups. You know about it if you heard about the “ cryptodoline in the canton of Zug ” - a non-profit association lobbying for the interests of crypto -business and blockchain projects. Today, such cryptomir giants as Ethereum and Xapo are based in the canton of Zug. Every week or two, Swiss Crypto Vally conduct mitapes and hackathons, in some of which we have already participated as representatives of Polybius. And if we decide to stay in Switzerland officially, it is in the canton of Zug.
There we met with the law firm Wenger and Vieli, working with fintek and cryptodol in the canton of Zug. They regularly and densely communicate with the local regulator and share with us the most recent data. Including, for example, this review of the state of regulation, which notes that Switzerland is one of the first countries that, at the regulator level, approved the use of the blockchain at a financial institution, provided that the auditor confirms its operational safety. This is exactly what we are going to do in Polybius: transactions inside the bank on a closed blockchain, and security and document circulation on Emercoin.
It is even more convenient to communicate with regulators through law firms than directly. On the one hand, it is faster than trying to go through some official channels "from the street", on the other - quite reliably, because in the future cooperation will still be conducted with the participation of the same lawyers: they will apply for licenses, and accompany the bank in the future.
Luxembourg is not only one of the banking centers of Europe. Their loyalty to Fintek is evidenced by the fact that as early as 2007, when Paypal needed a banking license in the EU, they received it in Luxembourg - there is an old friendship between the local regulator and Fintec. And what's good for Paypal shouldn't be bad for Polybius either.
In Luxembourg, there is one of the offices of the law firm Hogan Lovells, which is working to ensure that our ICO complies with US law. In order for the Polybius token to trade on American cryptobirds, it is necessary that the conditions of ICO do not contradict the American securities law. And lawyers at Hogan Lovells check the placement structure, documentation, and even the code of a smart contract for compliance with US laws. Their main task is to register disclaimers in such a way that the placement conditions do not fall under the definition of an IPO at all. For Hogan Lovells, this is not the first such project: in their portfolio there are examples of other successful ICO on American exchanges. And, most likely, we will cooperate with them if we dwell on Luxembourg as the country of incorporation of Polybius.
Another feature of Luxembourg is the presence of a separate regulator. In Switzerland, the financial markets regulator is the FINMA Financial Market Supervision Authority of Switzerland, in Finland this is done by the Financial Supervision Authority FIN-FSA, and in Luxembourg the Financial Sector Supervision Commission (fr. Commission de Surveillance du Secteur Financier, CSSF) . In Lithuania, financial supervision functions are fully included in the authority of the Central Bank.
From our point of view, the separation of the financial regulator and the Central Bank indicates a more developed financial market. The task of the Central Bank is to monitor the monetary system (control inflation, lending rates within reasonable limits), and the regulator looks at the general behavior of financial institutions. This requires different expertise - in the Central Banks, experts in macroeconomics are primarily engaged, and for the regulator it is most important to understand the structure of financial markets. These are adjacent areas, but still require a different set of knowledge.
Moreover, the separation of these functions reduces the state’s pressure on the economy: for example, if the Central Bank, for example, Russia, which also does not have a separate regulator of financial markets, wants to raise the lending rate, then, controlling banks, it can simply put pressure on them. In countries with the separation of these functions, the regulator is more likely to be on the side of banks, allowing you to organize a more economically balanced solution.
We are familiar with the Finnish Central Bank and communicate through our strategic advisor Hugo Bekis. Hugo is a distinguished financier who has built his career in a number of major banks, including Deutsche Bank and Bank of America, a member of the European Cybercrime Task Force. Through his contact with the Central Bank, we are planning to meet and establish business relations with FIN-FSA.
There are so few projects like us, and each case is unique. Therefore, when we reduce our list to at least two countries, we’ll go talk to the representatives of the licensing departments of the financial institutions of these countries personally, get to know them, introduce ourselves - and make the final decision.
Tax rate
Very simple, but very important parameter. In many European countries, a progressive income tax scale is used (more income - higher tax) for individuals. Say, Finland is famous for perhaps the highest taxes on millionaires and billionaires in the world, but at the same time, the scale of tax on legal entities' income there is flat, although quite high: 20%. In Lithuania, the scale is also flat - and the tax is 14.5%, in Luxembourg - a progressive tax from 15% to 29% depending on the size of the company, and in Switzerland - 14% for all.
Staff availability
Since the main (and, possibly, the only) office of Polybius will be opened in the country of incorporation, we need countries with sufficiently qualified labor force. In Switzerland and Luxembourg, this is easiest because both countries have a long banking tradition and a good economic education. In Lithuania and Finland, educational institutions for the production of the specialists we need are much less sharpened. At the same time, Switzerland is the most expensive country in terms of labor force. For the salary of one employee in Switzerland, you can hire, roughly speaking, three in Lithuania. Luxembourg and Finland are here - something like a golden mean, while Luxembourg stands out due to the quality of financial education.
Again, only on the basis of ICO and the type of license of a financial institution that we receive will the final set of financial services with which we start, and which categories of specialists we will need - and which ones we will need in the office, and what tasks we can outsource.
For example, it is already clear that everything related to security and banking transactions, including development, should be under our supervision. And support may be able to work remotely. At the same time, it is difficult to single out a separate EU country in which there would be an increased concentration of IT specialists, which means we will have to “import” them anyway. And to convince to move to Switzerland or Luxembourg, especially in the early stages of our business, will be much easier because of the quality of life. And in Switzerland, moreover, simplified obtaining a residence permit for qualified IT specialists is being discussed .
Therefore, if you have experience and knowledge in the areas of banking, financial institutions, legislation or blockchain technologies, you can contact us by mail at support@polybius.io and get into the Polybius team now.
Market access
Only three countries from our list are members of the European Union (Switzerland, traditionally, is neutral), but even within the EU, countries have different policies and views of regulators on the fintech industry and crypto-projects.
A company licensed by one of the EU regulators (Lithuania, Luxembourg, Finland) automatically gets access to all European markets at once. Some products may still require additional licensing - for example, p2p lending in Germany requires a local license, but with a basic European one, this is a minor problem. In Switzerland, we get only a local license. And in the case of the same p2p-loans, we will need to obtain licenses already in each country of the European Union.
Uniqueness
Other things being equal, each country is distinguished by something special. Switzerland is expensive, but it’s profitable in terms of reputation: the Swiss bank sounds solid. In Lithuania - cheap labor. In Finland, the most potentially friendly regulator. Luxembourg takes a combination of factors: not as expensive as Switzerland, but at the same level of financial development and advancement.
How to participate in the ICO "Polybius"
During ICO, Polybius tokens will be sold for $ 10 apiece with bonuses for earlier participation in the placement. These tokens will be distributed annually as a dividend of 20% of the annual, confirmed by European regulators of bank profits.
- On the first day of ICO, tokens will be sold with a 25% bonus on top, over the next four weeks, bonuses will gradually decrease.
- If you are afraid to miss the first day of ICO and wish to reserve tokens with the maximum bonus, please contact us by mail info@polybius.io
ICO "Polybius" until the end of spring. The exact date will be announced soon. In order not to miss this event, and to have time to purchase tokens in the first weeks, while there will be bonuses, subscribe to the newsletter with a notification on the website polybius.io .
Source: https://habr.com/ru/post/403209/
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