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Obtaining payment licences in Belize. Service offer

The provision of the following services requires separate licences in Belize:
- Money transmission services;
- Money brokering services;
- Payment processing services.

Requirements for the applicant

Requirements for the officers

The key issue is finding the director and shareholder for the company. There must be at least two approved officers to apply for a licence: director and shareholder.

The legislation that regulates financial licences in Belize does not set any special requirements for a shareholder or director of the company that applies for a licence (the Applicant), other than those described below.

The authority in charge of approval of candidates for the director and shareholder is the International Financial Services Commission (the IFSC); the decision is made after assessing a special affidavit which provides the information on the director/shareholder. The director / shareholder will need to meet the following criteria:

  • have no criminal record;
  • have not been previously refused the grant of a similar licence or had not such a licence revoked/suspended;
  • have not been declared bankrupt.

In addition to the Know Your Customer (KYC) affidavit, the following documents must also be submitted for each key person in the applicant company:

  • Valid ID document – notarized and apostilled copy;
  • Proof of address – not older than three (3) months at the time of application;
  • Financial reference (that meets the minimum requirements established by the Belize regulations on licensed financial activities);
  • Professional reference/Personal reference (that meets the minimum requirements established by the Belize regulations on licensed financial activities);
  • CV;
  • Certificates of qualification;
  • Evidence of due diligence checks (reporting any negative results).

In practice, the IFSC also pays attention to the work experience and education of the director/shareholder: an economic education and professional experience in investment or banking are preferable. These requirements are not described specifically, but, according to our practice, the required work experience includes managerial or other important positions.
The fit and proper test for the key persons in the company is quite demanding, but possible to meet, given a responsible approach to the finding and preparing of the relevant candidates that aims to satisfy as best as possible both formal requirements and the “discretion” of the Regulator.
The decision as to whether an applicant meets the fit and proper test is at the sole discretion of the IFSC. The IFSC does not comment on its decisions and they cannot be appealed against.

Also, the Applicant must:

  • pay the minimum authorized capital. Each of these types of licences requires a minimum authorized capital of USD 75 000 paid into an account at a Belize bank or, if it cannot be opened, at a financial institution in another country (the law provides certain restrictions). If a company applies for multiple licences at once, the authorized capital requirement may be higher – the IFSC can “add up” the required minimum authorized capitals for each licence, but may also request such a company to have the authorized capital higher than the total minimum;
  • provide a business plan describing the proposed activities in the next 5 years;
  • approve the internal documentation:
  1. Manual of Operating Procedure
  2. Money Laundering Prevention Controls Manual
  3. Complaints Handling Procedures
  • appoint a Compliance officer;
  • appoint an auditor and submit audited financial statements to the IFSC.

Applicant’s reporting requirements

According to the Standard Conditions for International Money Transmission Services Licence, Standard Conditions for International Payment Processing Services Licence, and Standard Conditions for Money Brokering Services Licence the Applicant, having received the appropriate licences, is required:

  • to comply with the International Financial Services Commission Act and the Regulations, as amended;
  • not to provide services to individuals or legal entities resident in Belize;
  • not to use the currency of Belize in its activities;
  • not to provide services to clients resident in countries whose laws require obtaining a local licence, except where such a licence is in place;
  • to seek the IFSC’s approval of all management positions / changes in the structure / other changes;
  • to report monthly (by the 10th of each following month or at such other times as may be specified by the IFSC) the total value of money exchanged;
  • to hold a meeting with IFSC representatives once a year in order to report on the activities in the past year and present a business operation plan for the next year;
  • for International Money Transmission Service Licence and International Payment Processing Services Licence, to pay special attention to transactions exceeding USD 10 000 (or equivalent in any other currency) and report all suspicious transactions to Belize Financial Intelligence Unit;
  • other.

The format of such a report is not defined by the IFSC; if the IFSC is not fully satisfied with the information submitted by the Applicant, the IFSC has the right to request comments and clarifications.

Other requirements for the Applicant

The Applicant cannot carry on business in a foreign country unless the Applicant is exempt from licensing or is licensed in that country.

The Belize Economic Substance Act and the changes that the Economic Substance Act has introduced to the legislation regulating licensed financial activities require a licensed company to have an office in Belize and at least one local director.

Our partner is ready to provide a director for your proposed company and arrange the rent of a local office for the company to comply with substance requirements.

Timeframe

The approximate time of company incorporation is 10 business days. The licence application takes approximately 4-6 months. Please keep in mind the time it takes to provide additional documentation or clarifications requested by the IFSC (these may vary from one case to another).

Fees for company incorporation and obtaining licences for Money transmission services, Money brokering services, and Payment processing services in Belize

Services
Fees (USD)[1]
Incorporation of the company (International Business Company, Belize) with an authorized capital exceeding USD 50 000
(including government fee and registered agent’s fees for the first year of the company’s existence, preparation and provision of the company’s original constitutive documents and an apostilled copy of such documents, documents issuing shares, as well as the company seal)
2 800
Payment of the authorized capital of the company
(minimum authorized share capital for one type of licence)[2]
75 000
Annual maintenance of the company (starting from the second year):
Government fee (higher fee for an authorized capital exceeding USD 50 000) + Registered agent’s fees (including registered office)
2 895
Local nominee director[3]
(does not include signing or courier shipments)
from 8 000 / year
Opening a Belize bank account (account with one signatory)
3 800
Supporting the licence application
Preparation and submission of an application for
· Money Transmission services licence
· Money brokering services licence
· Payment processing services licence
7 000 (for the first licence)[4]
3 000 (for each additional licence)
Application fee charged per application
(non-refundable; it is possible to apply for multiple licences in one application)
1 000
Annual licence fee
per licence, starting from the first year
5 000
Agent’s annual fee for liaising with the International Financial Services Commission (FSC)
from 600 (not more than 3 hours; after that, at the rate of 200 / hour)
Finding an office to rent
from 2 500
Office rent
from 700 / month
(must be paid for 2 months right away)
Drafting the AML Manual:
· Complaints Handling Procedures
· Manual of Operating Procedures
· Money Laundering Prevention Controls Manual
1 500 (standard)
+ 200 / hour if needs to be amended
Courier delivery of documents from/to Belize
250
Compliance fee
Payable in the cases of:
- incorporation of a company,
- renewal of a company,
- liquidation of a company,
- transfer out of a company,
- issue of a power of attorney to a new attorney,
- change of director / shareholder / beneficial owner, except the change to a nominee director / shareholder),
- signing of documents.
350 (standard rate, includes the check of 1 individual),
+ 150 for each additional individual (director, shareholder, or beneficial owner) or legal entity (director or shareholder) if such legal entity is administered by GSL,
+ 200 for each additional legal entity (director or shareholder) if such legal entity is not administered by GSL,
450 (rate for high-risk companies, includes the check of 1 individual)
100 (signing of documents).

Additional services[5]

Services
Fees (USD)

Certificate of Good Standing

original
320
apostilled original
920

Certificate of Incumbency

original
300
apostilled original
900
Copy of Certificate of Incorporation certified by the registered agent of the company
140
Copy of Memorandum & Articles of Association certified by the registered agent of the company
140
Copies of other corporate documents certified by the registered agent of the company (per document)
90
Notarial certification and apostille of a document
465

[1] The fees are valid at March 2023 and may change without prior notice.

[2] If a company applies for multiple licences at once, the authorized capital requirement may be higher – the IFSC can “add up” the required minimum authorized capitals for each licence, but may also request such a company to have the authorized capital higher than the total minimum.

[3] The director’s final fees are determined after agreeing the specific responsibilities of the director.

[4] In the case of applying for multiple licences; when applying for one licence, the application supporting fee is USD 9 500.

[5] The fees are valid at March 2023 and may change without prior notice.

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