App rejected regarding cryptocurrency exchange license

We got this rejection for our cryptocurrency exchange app:

The issues we previously identified still need your attention. Specifically, we need licensing for these storefronts you provided info in your notes.

Alternatively, you may provide an opinion from your legal counsel confirming your authorization to provide these services in all salable territories, and provide this attachment in your resubmission.

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.

Our app is only targeting a country (India) that does not require any license in order to operate a cryptocurrency exchange. The App Store review team says we may provide a legal opinion for this, but when speaking with lawyers about this, they say that they've written legal opinions for other clients in the past, but Apple has still insisted on a business license, even after receiving such a letter.

My questions:

  • Should we provide a legal opinion, which states that India does not require a license in order to provide crypto exchange services?
  • If we provide this legal opinion, will Apple accept it and approve our app for India?
  • If not, how are the other crypto exchanges (like Binance, etc.) listed on the App Store in countries that don't require a license?
Post not yet marked as solved Up vote post of jeffsun Down vote post of jeffsun
2.7k views
Posted by
jeffsun
Reply
Add a Comment

Replies

Hello,

"but Apple has still insisted on a business license, even after receiving such a letter."

Are you an individual or a company? Is your company a "financial" company?

Posted by
matheymatei
Up vote reply of matheymatei Down vote reply of matheymatei

  • Yes, our legal entity is a company (not an individual), so it is a business. (The company is a cryptocurrency exchange, so we are "financial" in the sense that we handle user's funds).

    The "business license" mentioned above refers to a special license to operate a cryptocurrency exchange in a given country. Some countries require such a license, but some don't.

    —
    jeffsun

  • Our legal entity is a company, and the company is a cryptocurrency exchange - what do you mean by "financial" company?

    The "business license" mentioned above refers to a special license that some countries require, in order to provide cryptocurrency exchange services.

    —
    jeffsun
Add a Comment

@matheymatei Our legal entity is a company (a cryptocurrency exchange) - is that what you mean by "financial" company?

The "business license" mentioned above refers to a special license that some countries require for providing cryptocurrency exchange services.

Posted by
jeffsun
Up vote reply of jeffsun Down vote reply of jeffsun
Add a Comment

India crytpo is mad shady so a legal opinion of 'the mob says lawless is ok' may not be enough if you catch my drift

Posted by
const_void
Up vote reply of const_void Down vote reply of const_void
Add a Comment

@jeffsun

If your legal entity is a cryptocurrency exchange then it's best for you to provide the documents that Apple requires from you. There is no other way. If you will or not be approved on the App Store, nobody knows but chances are significantly higher if you do what Apple asks.

Additionally to everything, note that cryptocurrency apps are a grey area and in the end, Apple decides best in its own interest (know that Apple will protect its users first). It's different if the app is submitted by a big company that already established a cryptocurrency business on its own website (ex. Binance) or just a recently registered crypto exchange.

Hope you resolve your issue.

Best

Posted by
matheymatei
Up vote reply of matheymatei Down vote reply of matheymatei
Add a Comment

We are facing the same problem and every time we ask for a clear explanation of what exactly Apple wants from us however they are repeating same text as yours again and again.

The actual problem is if they prohibited cryptocurrency apps we should know this and/or if they will only approve apps that hold licenses %90 of the countries do not issue any licenses so Apple should indicate which countries need licenses and which countries do not need these. How can we get licenses from the countries even if they do not issue licenses at all?

This approach is not a good behavior to their customers even though we pay a yearly fee to take these services. However even we can not get a clear answer to our problem. The question is simple why don't you approve our app? What is the problem? And what should we do to get approval?

Disappointing behavior against us without a clear explanation and apart from the world's reality.

If anyone gets a clear explanation please share it with us may be someone get a solution with trials where Apple does not help us and gives clear explanations formally.

Posted by
Byte123
Up vote reply of Byte123 Down vote reply of Byte123
Add a Comment

We’re currently facing this same sad situation. It appears the app review team at Apple is made up of robots because they keep sending the same replies despite all your explanations. We currently operate in a country where no crypto licenses are issued, how exactly does Apple expect us to come up with a license?

The crazy thing is that our app is already in the App Store, Apple has been approving all our updates before now, suddenly we can no longer update the app because Apple wants a license which we don’t know where to get.

I'm beyond ******.

Posted by
YNW
Up vote reply of YNW Down vote reply of YNW
Add a Comment

Has anyone tried the FINCEN MSB license, can it pass the apple store review?

Posted by
john2023
Up vote reply of john2023 Down vote reply of john2023
Add a Comment