Hi everyone,
We have submitted a non-custodial cryptocurrency wallet and have been working with Apple to have it approved.
They have rejected the app based on:
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. 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.
Our response:
Our app does not facilitate the transfer of virtual currencies or provide an exchange service. Our app is a non-custodial wallet. We do not store any assets or private keys of users. Our app is just a client (interface) to a decentralized network that helps users generate their own private and public keys and store them on their mobile device. We are not providing any form of regulated service in any jurisdiction.
Do we provide an exchange?
We don't provide an exchange ourselves. We do have a "buy" button in the app but this links directly to a 3rd party onramp using the Safari browser overlay. If a user wants to do an exchange / buy cryptocurrency they can perform this independently with the regulated onramp.
Our app is very similar to other products on the market who also have browser links to 3rd party onramps. Mainly:
- TrustWallet
- Spatium Wallet
How can we respond to Apple? It would not be feasible to have a legal opinion written by lawyers in X number of jurisdictions.
Does anyone have experience with non-custodial cryptocurrency wallets and Apple?
Thank you in advance.