El Salvador

Key Requirements

• Comply with AML/CFT requirements including customer due diligence, transaction monitoring, and suspicious activity reporting to CNAD.
• Establish local representative or subsidiary in El Salvador with physical office and operational personnel.
• Implement governance structure with board oversight, compliance officer, and internal audit procedures.
• Establish cybersecurity infrastructure meeting CNAD standards including multi-signature wallets and cold storage for custody services.
• Implement customer protection procedures including fund segregation, insurance coverage, and dispute resolution mechanisms.
• Maintain regular reporting to CNAD including transaction volumes, customer complaints, and operational incidents.

Application Process

1. 1.Prepare detailed business plan describing service offerings, operational structure, and customer protection procedures.
2. 2.Submit DASP license application to CNAD with documentation of capital adequacy of USD 2,000 minimum.
3. 3.Provide evidence of AML/CFT compliance program and customer due diligence procedures.
4. 4.Submit cybersecurity assessment and operational resilience plan including incident response procedures.
5. 5.Provide local representative information and office location documentation in El Salvador.
6. 6.Receive CNAD approval and commence DASP operations.

Ongoing Obligations

• Maintain minimum capital of USD 2,000 with quarterly capital adequacy reporting to CNAD.
• Submit monthly transaction reports including trading volumes, user numbers, and incident disclosures.
• Conduct annual compliance audits documenting AML/CFT procedures, customer protection, and operational effectiveness.
• Report material incidents including cybersecurity breaches, fraud, or customer fund loss within 24 hours.
• Maintain customer fund segregation with quarterly reconciliation and audit verification.
• Update CNAD of material changes to business model, ownership, or service offerings within 30 days.

Key Requirements

• Register business entity with El Salvador Ministry of Commerce with Bitcoin service activities specified.
• Implement AML/CFT procedures including customer identification and transaction monitoring per Bitcoin Law requirements.
• Establish customer communication procedures for transaction confirmation and dispute resolution.
• Maintain audit trail and transaction records for minimum 5 years with documentation of conversions and transfers.
• Implement security measures protecting customer Bitcoin holdings including wallet security and backup procedures.
• Report monthly operational status to Ministry of Commerce including transaction volumes and any incidents.

Application Process

1. 1.Register business entity with El Salvador Ministry of Commerce specifying Bitcoin service activities.
2. 2.Submit written AML/CFT compliance procedures and customer identification requirements.
3. 3.Provide operational procedures documentation including transaction processing and record keeping.
4. 4.Submit evidence of security measures for Bitcoin holdings and customer fund protection.
5. 5.File Bitcoin Service Provider Registration form with Ministry of Commerce.
6. 6.Receive registration approval and commence Bitcoin service operations.

Ongoing Obligations

• File monthly operational reports with transaction volumes, customer accounts, and any regulatory violations.
• Maintain customer records including identification, transaction history, and dispute resolution for 5 years minimum.
• Conduct annual compliance review addressing AML/CFT procedures and customer protection effectiveness.
• Report suspicious transactions or fraud attempts to Ministry of Commerce within 10 days.
• Maintain security procedures for Bitcoin holdings with quarterly verification and testing.
• Notify Ministry of Commerce of material changes to business model or ownership within 15 days.