Guideline 3.1.5 - Business - Payments - Cryptocurrencies

Hello,

My app was Rejected for this reason :

Guideline 3.1.5 - Business - Payments - Cryptocurrencies

Your app facilitates the transmission of a virtual currency but was not submitted by a corresponding exchange or recognized financial institution.

Next Steps

To resolve this issue, please provide documentary evidence demonstrating you have the necessary licenses and permissions to distribute an app with cryptocurrency exchange features in all the locations where your app is currently available.

Your app must be published under a seller name and company name that reflects the Phemex name. If you have developed this app on behalf of a client, please advise your client to add you to the development team of their Apple Developer account. If your client does not yet have an Apple Developer account, they can enroll in the Apple Developer Program through the Apple Developer website.

  1. We currently only have licenses from a few countries.
  2. Our app sales countries have chosen 1-2 hundred countries, and we cannot provide licenses for most countries, and many countries do not provide virtual currency exchange licenses.
  3. If the sales scope is narrowed, the impact will be too great.

We don't know what to do next to solve this problem

I know that the app review rule 3.1.5 Cryptocurrencies has been updated recently:

(iii) Exchanges: Apps may facilitate transactions or transmissions of cryptocurrency on an approved exchange, provided they are offered only in countries or regions where the app has appropriate licensing and permissions to provide a cryptocurrency exchange.

What I don't understand is whether it restricts all transactions in virtual currency or only the exchange of funds in virtual currency without a license

You have no choice but:

  • restrict to those countries where you get licence
  • manage to get licences for all the countries.
  • give up your app.

And reviewer will be extremely strict on this.

It seems you have a second issue with the developer account that registers the app.

I noticed 3.1.5 Cryptocurrencies

(iii) Exchanges: Apps may facilitate transactions or transmissions of cryptocurrency on an approved exchange, provided they are offered only in countries or regions where the app has appropriate licensing and permissions to provide a cryptocurrency exchange.

The title of this rule is Exchanges, but I don't know if it restricts the exchange of virtual currency or restricts transactions? If I only remove the exchange function, can it meet the requirements?

Can you tell me how you get your license ? we have the same problem like yours, but we haven’t any license, and we don’t know what we can do next.

can BitLicense solve this issue?

We are facing a similar issue and was wondering if you have made any progress in finding a solution. If not, would you be willing to discuss the issue further and share any insights you have?

you sovle this question? i have same

Hello, may I ask how the national license was handled and how it was finally put online? I have the same problem to solve. Please answer it. Thank you

Have you tried the FINCEN MSB license, does it work?

Has anyone tried the FINCEN MSB license? Can you share your experience?

Anyone have any more insights in this? I do see larger crypto exchanges like binance and crypto.com offering their apps in countries they do not have a license.

Hello all, has any one been able to sort this out with any preferred licensing or approach. I need any assistance with this issue as it is really affecting the business currently. Thanks

Guideline 3.1.5 - Business - Payments - Cryptocurrencies
 
 
Q