Overview

In late 2023, the UK regulator expanded Financial Promotions regulations to include providers of crypto-related services. Although BVNK may not appear as offering investment services, BVNK’s crypto services are captured by the new regime and compliance with this regulation is essential for our business and UK-based customers to continue accessing our crypto services.

This means that we need to collect some additional information from you, to verify that our services are suitable for your company. "Company" being the legal entity that is a UK-domiciled firm and a customer of BVNK.

Here are some resources to help you understand the new requirements better.

What are the mandatory steps to access our services?

Before we can provide you with access to our services, we will need to take you through the following steps:

• Standard risk warning
• 24-hour cooling-off period
• Personalised risk warning
• Client categorisation
• Appropriateness assessment 

What is the standard risk warning? 

We are required to include a mandatory risk warning on our website. You will see a banner at the top of our website and apps which is needed to comply with the Financial Conduct Authority (“FCA”) requirements. This standard risk warning can also be accessed here. Take 2 mins to learn more.

What is a personalised risk warning? 

This risk warning is similar to the standard risk warning described above; however, it will be personalised to you. Again, this is needed to comply with the FCA requirements. This personalised risk warning will be displayed to you should you be offered and wish to take up a Direct Financial Promotion. 

What is the 24-hour cooling-off period? 

Before providing you access to our products, as a first-time customer, we are required to implement a 24-hour cooling-off period. This means that you will be unable to access our products until the 24-hour period has passed. This is done to allow you, the merchant, an opportunity to consider the products and services that we provide. 

You will still be able to proceed with other parts of the investor journey during the cooling-off period (e.g. client categorisation and appropriateness assessments which are described further below).

What is self-categorisation? 

Before we can allow you to use BVNK products, you will be required to self-categorise yourself and confirm your current and personal circumstances. This helps us understand the nature of our clients and also ensure that the products on offer are appropriate for you. 

There are two categories available for you to choose from. These are based on your personal circumstances. Further information on the categories and examples of the declaration for self-categorisation that need completing can be found below:

• Restricted investor 
• High net worth investor 
• Certified Sophisticated Investor

A Restricted Investor  maintains a vigilant investment approach, abstaining from allocating over 10% of their assets to high-risk investments over the past 12 months, with no intention to exceed this threshold in the upcoming 12 months*.

A High Net Worth Investor has an annual income* of £170 000 or more per year, or has net assets* of £430 000 or more.

The Financial Promotion regime requires all users to self-select into one of the two categories from 8 January 2024, otherwise:

• New users can't be onboarded
• Existing users can't buy or trade crypto assets (but can still sell crypto for cash, withdraw cash, or send crypto to an external wallet address)

A Certified Sophisticated Investor received, in the last 3 years, a certificate from an authorised firm confirming they understand the risks involved in crypto assets. This certificate must be submitted to BVNK for the purpose of the categorisation.

Customers must repeat Client Categorisation every 12 months.

* net assets do NOT include: your home (primary residence), your pension (or any pension withdrawals) or any rights under qualifying contracts of insurance.

High-risk investments are: peer-to-peer (P2P) loans; investment based crowdfunding, units in a long-term asset fund; cryptoassets (such as bitcoin); and unlisted debt and equity (such as in companies not listed on an exchange like the London Stock Exchange).

Income does NOT include any one-off pension withdrawals. Net assets do NOT include: your home (primary residence), any loan secured on it or any equity released from it; your pension (or any pension withdrawals), or any rights under insurance contracts.

Will I need to self-categorise myself again? 

The categorisation only lasts for 12 months, and if you wish to continue accessing our products, you will need to re-confirm your category towards the end of each 12-month period. This is to account for any changes in life circumstances which may affect how you can be categorised.

When should I complete the self-categorisation?

Once you create an account with us you will be prompted to complete the self-categorisation. This can be completed in parallel with BVNK’s Know Your Customer (KYC) and onboarding processes.

What is the appropriateness assessment?

What happens if I fail the assessment questionnaire? 

if you do not successfully complete the assessment questionnaire the first time around then you will be permitted to make another attempt immediately. If you are unsuccessful on the second attempt, you can try again after 24 hours. 

You will have three attempts to complete the questionnaire. After three attempts, if you do not successfully complete the questionnaire, we will be unable to offer you access to our products. 

How can I prepare for the assessment questionnaire? 

We have prepared some educational material to help you understand the risks involved with our products and how to mitigate them if you have yet to learn them.  This will assist in understanding the types of questions we will ask you in the assessment questionnaire.  

When should I complete the appropriateness questionnaire?