NexusFTx: exchange licensing stack for Hong Kong and the Bahamas

Business plans, a financial model and AML/CFT controls for a crypto exchange applying for licences under Hong Kong’s SFC regime and the Bahamas DARE Act.

Client
NexusFTx
Service
Licensing documents
Period
Exchange licensing engagement
Review
5.0 on Upwork

Client documents

Confidential. Not published here; available to prospective clients under NDA.

  • NDABusiness plans, Hong Kong and Bahamas
  • NDAFinancial model
  • NDAExchange architecture
  • NDAHelp-centre content: FAQs, user, trade and margin guides

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The brief

NexusFTx planned a regulated exchange offering spot, perpetuals and custody in two jurisdictions at once. Each regulator wanted to see a credible business, a funded operating plan and controls that matched local rules, and the two sets of documents had to stay consistent with each other.

What I did

  • Licence architecture for SFC Type 1 and Type 7 approvals alongside Bahamas DARE registration
  • Business plans for Hong Kong and the Bahamas, plus a token listing policy
  • Risk controls covering market risk, AML red-flag rules, custody and fund segregation via a trust structure
  • Onboarding logic aligned with AMLO, JFIU and FATF guidance
  • Financial model of $114M three-year trading volume, with revenue and cost split and operating runway
  • Separate token filtering for professional and retail investors

Frameworks and tools

  • SFC Type 1 and 7
  • Bahamas DARE Act
  • AMLO
  • FATF
  • Excel

Outcome

  • A complete dual-jurisdiction documentation stack, from business plan to governance and staffing model
  • Clients across the Singapore, Bahamas and Hong Kong exchange work rated the engagement 5.0, citing independent execution and quality