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Crypto License

Crypto License in Bosnia

Set up your crypto business and VASP registration in Bosnia and Herzegovina

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Service Snapshot

Regulatory & Service Snapshot

Gofaizen & Sherle helps you choose where to set up your crypto business in Bosnia and Herzegovina, form the company and prepare your application for virtual asset service provider (VASP) registration. The requirements depend on your company’s location and the services you plan to offer. In Republika Srpska, providers must be entered in an official register. This registration is not a separate license to operate.

  • Route and Authority Republika Srpska Securities Commission record
  • Company Local limited liability company (d.o.o.), or an eligible branch structure
  • Formation Capital RS limited liability company: 1 BAM
  • Local Presence Address and staffing arrangements assessed for the chosen structure
  • Preparation Offer estimate: 2 weeks before incorporation
  • Service Price Packages from €6,500, with scope confirmed individually
  • Tax 10% corporate income tax on taxable profits
  • EU Passporting Not provided
  • Service Result Corporate setup and filing support, separate from authority and bank decisions

Who Should Consider This Route?

sign positive

May fit

  • businesses seeking a non-EU base for exchange, custody or transfers
sign warning

May not fit

  • projects requiring EU passporting under the Markets in Crypto-Assets Regulation (MiCA), or other financial permissions

Requires review: international platforms, complex token issuance and mixed payment models

Which Regulatory Route Does Your Project Need?

RouteWhen It Applies
Republika Srpska (RS) Authority: RS Securities Commission; Mechanism: Provider record; Service scope: Listed virtual-currency services; Verification status: Confirmed
Federation of Bosnia and Herzegovina (FBiH)Authority: FBiH Securities Commission; Mechanism: Statutory AML supervision; Service scope: VASP activities; Verification status: Comparable registration procedure not verified.
Brčko DistrictAuthority: Directorate of Finance, Tax Administration; Mechanism: Statutory AML supervision; Service scope: VASP activities; Verification status: Filing requirements need confirmation.

The Republika Srpska Securities Commission also supervises companies based elsewhere that offer services through a branch in Republika Srpska. It checks that they follow AML/CFT rules and lists registered providers in its official register.

What Changes Between Territories?

  1. RS — Additional setup check: D.o.o. formation capital: 1 BAM. Assess registered address, staffing and branch requirements.
  2. FBiH — Additional setup check: D.o.o. formation capital: 1,000 BAM. Confirm local registration and operational requirements.
  3. Brčko District — Additional setup check: Confirm district incorporation, tax registration and applicable filings.

These are corporate capital rules, not a budget for running regulated activities.

Which Activities Can Be Covered?

The national AML framework covers services provided for others:

  1. Exchange
    Exchanging cryptocurrency for fiat or another cryptocurrency
  2. Custody
    Holding or controlling customers’ virtual currencies
  3. Trading platforms
    Organizing virtual-currency trading
  4. Transfers
    Receiving and executing customer transfer orders
  5. Services for token issuers
    Providing financial services to help another business offer or sell its virtual currency

Issuing your own token, tokenizing an asset or supporting an initial coin offering (ICO) requires a separate review. The rules depend on what the token represents and your business’s role in the project.

What Will Gofaizen & Sherle Handle?

Licensing support covers defined deliverables:

  1. Assessment & Structure

    • Regulatory assessment and business-structure selection
  2. Registration & Documentation

    • Company setup and corporate documentation
  3. Compliance Framework

    • AML and know-your-customer (KYC) policies, risk controls and AML officer recruitment support
  4. Operational Readiness

    • Application support, filing and responses to authority requests
    • Banking readiness and agreed ongoing compliance support

Registries and the Commission make their own decisions. Management and the money laundering reporting officer (MLRO) remain responsible for implementation.

What Does the Service Cost?

Gofaizen & Sherle’s offer sets out these packages. Confirm scope and charges before engagement.

Full

€13,900

Everything in Advanced plus:

  • director’s local residence-registration certificate (“white card”) support
  • KYC/transaction-monitoring provider setup
  • office space for one year
  • a legal opinion on company status

Advanced

€9,900

Everything in Basic plus:

  • apostille/English translation
  • European electronic money institution (EMI) application support
  • AML officer recruitment/employment documentation
  • tailored policy

Basic

€6,500

  • Incorporation including government/notary fees
  • address for one year
  • filing support
  • local special-purpose account assistance
  • Serbian corporate documents
  • standard AML/KYC policy

The Commission’s 2026 fee schedule sets a one-time registration fee of 3,000 BAM and an annual supervision fee of 1.2% of total revenue, subject to a minimum of 2,000 BAM per year.
The process for setting up and registering a VASP in Republika Srpska has five stages. Some tasks can run in parallel.
The final quote must distinguish professional fees, official charges and third-party expenses. Confirm treatment of the Commission fee, translations, bank charges, MLRO salary, accounting and address/office renewals. Package prices are not the total operating budget.

What Are the Steps to Register a VASP?

  1. Assessment

    You describe your services and target markets. Gofaizen & Sherle identifies the requirements and helps choose a company structure.

  2. Company Formation

    Gofaizen & Sherle prepares the documents. You provide information, sign and pay the share capital. The registration authority reviews the application and registers the company.

  3. Compliance Preparation

    Gofaizen & Sherle prepares AML/CFT policies and compliance officer documents. Your management appoints the officer and implements the procedures.

  4. Application and Review

    Gofaizen & Sherle submits the application and help answer follow-up questions. The Republika Srpska Securities Commission decides whether to register the company.

  5. Launch Preparation

    Gofaizen & Sherle supports bank applications and, where included, KYC/KYT provider arrangements. The bank decides whether to open an account. Your team ensures the platform and compliance procedures are ready before launch.

What Do We Need From You?

  • holder

    Ownership & Management

    Founder, shareholder, ultimate beneficial owner and director identification, residence and background documents
    Ownership chart, existing corporate records and source of funds

  • structure

    Business Model

    Business model, activities, customers and target markets

  • fintech

    Transactions & Markets

    Fiat/asset flows, expected volumes and banking needs

  • doc info

    Compliance & Banking

    Existing policies, technology arrangements and intended launch date

Our expertise

Why Gofaizen & Sherle?

We combine legal, regulatory and technical expertise to support businesses navigating complex regulatory requirements from initial assessment to implementation.

  1. Corporate structuring Company formation and cross-border business setup.
  2. Financial regulations Application preparation and regulator-facing documentation.
  3. Compliance & Governance AML/CTF frameworks and post-authorisation support.

What we handle

  • w assessment Project assessment
  • w structuring Structuring & Classification
  • w documentation Documentation
  • w implementation Implementation support
Mark Gofaizen

Mark Gofaizen

Senior Partner, Head of Consulting

mark@gofaizen-sherle.com
Maksim Gasanbekov

Maksim Gasanbekov

Partner, Head of Sales (Crypto and Blockchain)

maksim@gofaizen-sherle.com

How Long Does VASP Registration Take?

Gofaizen & Sherle provides the following estimates for setting up and registering a VASP in Republika Srpska:

  • Preparation

    We collect your information, confirm the planned activities and prepare the initial documents. Timing depends on receiving complete documents and signatures from you.

    Timeline: 2 weeks

  • Company Formation

    We prepare and submit the incorporation application. Completion depends on the notary, registration authority and bank handling the share capital deposit.

    Timeline: 2–3 weeks

  • VASP Registration

    This is the estimated time to prepare the compliance documents and submit your application to the Securities Commission. The Commission’s review may take longer if it needs further information.

    Timeline: 4–5 weeks

These are planning estimates, not guaranteed deadlines. Bank or EMI account applications follow a separate schedule determined by the provider. Your launch date also depends on completing registration and having the necessary operational arrangements in place.date. Bank/EMI onboarding has a separate timetable. Incomplete documents or authority questions can extend the process.

Effective from 13/2024

Which Laws Apply to Your Crypto Business?

Your business must follow Bosnia and Herzegovina’s AML/CFT law, along with the rules that apply where it is established and provides services—Republika Srpska, the Federation of Bosnia and Herzegovina or Brčko District.

  1. BiH AML/CFT Law, 13/2024 — Authority: Territorial supervisors and SIPA’s Financial Intelligence Department; Main function: Customer checks, monitoring and reporting.
  2. RS Securities Market Law, Article 260b — Authority: RS Securities Commission; Main function: Provider record and supervision.
  3. RS record rules, 4/23, 82/24, 112/25 — Authority: RS Securities Commission; Main function: Filing information and supporting evidence.

Current Regulatory Status

Confirmedthe Commission’s May 27, 2026 notice distinguishes record entry from operating approval
Territory-dependentNational AML obligations do not establish identical filing procedures everywhere
Before filingcheck current forms, officer evidence and the 2026 fee tariff

What Continues After Registration?

  1. Review money-laundering risks, verify customers’ identities, monitor transactions and report suspicious activity
  2. Keep business and compliance records, and notify the relevant authority of changes to ownership or designated officers
  3. Maintain the responsible AML function and staff training
  4. Submit RS annual risk reports and financial filings, with audits where required
  5. Budget for supervision fees and ongoing compliance

Obligations depend on services, territory and customer risk:

The RS reporting requirements are set out in the Commission’s current reporting rule.

What Taxes Will Your Company Pay?

Tax residence and transaction treatment matter alongside headline rates.

Corporate income tax: 10% on taxable profits in RS, FBiH and Brčko

VAT: Standard rate: 17%. Assess each service and any applicable exemption

Dividends: Check recipient status, applicable territorial rules and treaties

VAT treatment depends on the type of crypto transaction, while taxes on profit distributions depend on the applicable rules and the recipient’s circumstances.

What Could Prevent a Lawful Launch?

  • Providing RS services before entry in the record
  • Failing AML controls or reporting duties
  • Treating registration as permission for unrelated products
  • Serving foreign markets without checking their requirements

How Does Banking Support Work?

Banks, electronic money institutions (EMIs) and payment service providers (PSPs) make their own account decisions.

  1. Owners and source of funds — Gofaizen & Sherle supports: Evidence preparation.
  2. Countries, counterparties, volumes and flows — Gofaizen & Sherle supports: Business-model explanation.
  3. Compliance and account purpose — Gofaizen & Sherle supports: Application documentation.

A capital-deposit account, an operating account and a client-funds account serve different purposes. One does not replace the others.

Which Alternatives Should Be Compared?

MarketModel and market access Capital basisBest fit
Bosnia, RSProvider record, no MiCA passportD.o.o.: 1 BAMNon-EU base
MontenegroCommission registration, no MiCA passportConfirm for chosen structureAlternative regional base
EU MiCACrypto-asset service provider (CASP) authorization and cross-border notificationCapital basis: €50,000/€125,000/€150,000 service-class thresholdsEU expansion
SwitzerlandModel and market access: Self-regulatory organization (SRO) affiliation where applicable, no MiCA passportGmbH: CHF20,000, additional rules may applySwiss financial intermediary.

MiCA safeguards must meet the higher of the relevant threshold and one quarter of annual fixed overheads. Corporate formation capital and regulatory safeguards are different measures.

Frequently Asked Questions

Can foreign founders own the company?

Yes. RS company-formation rules allow foreign individuals and companies as founders. Gofaizen & Sherle can assess the ownership structure and required evidence before incorporation. Foreign owners will need to provide identification, information about the source of their funds and the required documents for the company’s director.

Can everything be completed remotely?

Some company formation steps can be handled remotely through a notarized power of attorney. However, the director may need to visit Republika Srpska to complete local formalities and open a bank account. Gofaizen & Sherle will clarify which steps require a visit so you can plan ahead.

Does a small team need a separate MLRO?

The staffing arrangement needs assessment. The RS rules allow a declaration for businesses with four or fewer employees. This does not remove AML responsibilities. Gofaizen & Sherle can assess the applicable arrangement and prepare officer documentation.

Client Testimonials

Trusted by Industry Leaders

At Pilsenga since the very beginning we counted with Gofaizen & Sherle to build our financial institution in 21 days, we started our operations in record time thanks to them, it's been pleasant to work with them through the rush of building a Financial Institution in record time. They for real understand compliance and crypto businesses!

pilsenga logo Victor Romero CEO - UAB Pilsenga
Skailenga UAB Case study

Skailenga UAB

Services Provided: End-to-end VASP and MiCA licensing support in Lithuania, including share transfer, corporate structuring, AML/KYC framework development, FNTT reporting, legal advisory, HR recruitment, payroll, and accounting services.

Read case

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Mark Gofaizen
Mark Gofaizen
Senior Partner, Head of Consulting
Maksim Gasanbekov
Maksim Gasanbekov
Partner, Head of Sales (Crypto and Blockchain)
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