# Map your crypto-payment flows before choosing a licensing route

This FOL guide helps you prepare the business facts and questions for a licensing consultation. [Explore FOL crypto-licensing services](https://fastoffshorelicenses.com/crypto-license/).

A crypto-payments business should map every movement of money and crypto-assets before comparing licensing routes. Show who sends and receives each asset, who controls it, where each participant is based, and which providers handle conversion or settlement.

This gives your adviser facts to assess. Company incorporation, business or AML registration, and a licence or authorisation answer different questions. One does not automatically provide the others or establish permission to serve every target market.

## Start with the people and businesses in the flow

List every participant. Use legal names where known and mark proposed providers as unconfirmed.

| Participant | What to record |
| --- | --- |
| Operating company | Legal entity, incorporation, owners, management and role |
| Customer | Individual or business, location, and whether they send, receive or store value |
| Merchant | Legal location, customer markets, accepted assets and settlement preference |
| Counterparty | Exchange, liquidity provider, broker or other transfer or conversion party |
| Custody provider | Who controls wallets or keys, where, and when control starts and ends |
| Bank or electronic money institution (EMI) | Account holder, location, currencies, collection or payout role and onboarding status |
| Technology provider | Service, assets or data handled, contractual customer and subcontractors |

Do not combine several companies under a group or brand name. Your adviser needs to see which legal entity performs each activity and has each customer or provider contract.

## Complete one step sheet for every movement of value

Break the service into numbered steps from the first customer instruction to final settlement. Copy the two-column form below once for each step. Create separate step sheets for fees, refunds, failed transactions, reversals and withdrawals where they occur. Each sheet describes one movement of value.

| Field | Your answer |
| --- | --- |
| Step and event | What triggers this step? |
| Sender and location | Who sends the asset, and from which country? |
| Receiver and location | Who receives it, and in which country? |
| Asset in | Fiat currency, crypto-asset or token received |
| Asset out | Fiat currency, crypto-asset or token delivered |
| Account or wallet | Whose name is on it, or who controls the keys? |
| Conversion | Does the asset change? Who executes the conversion? |
| Holding and fees | How long is value held? Who charges and pays each fee? |
| Provider | Which bank, EMI, custodian, exchange, processor or other provider handles the step? |
| Customer market | Where is the relevant customer or merchant based? |
| Contract | Which entity contracts with the customer and providers? |
| Regulatory question | Which possible obligation needs assessment for this step? |
| Open question | Which fact or provider decision needs confirmation? |
| Evidence or source | Link to the supporting contract, diagram or provider confirmation; record its date and version, or mark it missing |
| Owner | Who will obtain or confirm the missing facts? |
| Status | Confirmed, to confirm, or not applicable; explain unresolved items |

Keep a separate flow index containing each step number and a short label. Connect those numbered steps with arrows, so the reader can find the corresponding sheet. If a step branches into several paths, such as merchant settlement in fiat or stablecoins, number and map each path separately.

## Add the operating facts around the flow

Record who performs customer onboarding, identity checks, transaction monitoring, sanctions screening, fraud controls, complaints, reconciliation, incident response and record keeping. Identify the system and accountable person for each task.

List the countries where you plan to market or accept customers. Keep those markets separate from the place of incorporation and provider locations. Ask your adviser to assess the activity and territorial reach of each legal entity. A licence label alone does not answer that question.

## Hypothetical example

Consider a fictional company planning to help online merchants accept stablecoin payments. A customer pays from a self-hosted wallet. A third-party provider screens the transaction. A custodian-controlled wallet receives the stablecoins. A liquidity provider converts some settlements into euros, and an EMI pays the merchant's business account.

For the euro-settlement path, a short flow index could read: **1. Customer stablecoin transfer to the custodian-controlled wallet → 2. Conversion into euros → 3. EMI payout to the merchant.** Record transaction screening as a control alongside the relevant step. Add any fee, refund or failure paths separately.

Here is a compact example of the step 1 sheet. It uses only the fictional scenario above; unresolved details remain visible.

| Field | Illustrative answer |
| --- | --- |
| Step and event | 1. Customer stablecoin transfer to the custodian-controlled wallet |
| Sender and location | Customer using a self-hosted wallet; country to confirm |
| Receiver and location | Custodian-controlled wallet; receiving legal entity and country to confirm |
| Asset in and out | Stablecoins received; no conversion in this step |
| Account or wallet | Custodian controls the receiving wallet; exact arrangements to confirm |
| Conversion | None in this step; euro conversion is step 2 |
| Holding and fees | Holding period, fee payer and charges to confirm |
| Provider | Proposed custodian; legal name and agreement to confirm |
| Customer market | Customer and merchant countries to confirm |
| Contract | Contracting entities and allocation of responsibilities to confirm |
| Regulatory question | What obligations, if any, follow from each entity's role in receiving or controlling the assets? |
| Open question | Who can instruct a transfer from the receiving wallet? |
| Evidence or source | No real evidence in this fictional example; obtain the proposed custody agreement and wallet-control diagram |
| Owner | Founder to obtain provider documents for the adviser's assessment |
| Status | To confirm; this illustrates an incomplete preparation sheet, not a validated operating arrangement |

The flow map raises separate questions: which entity contracts with the merchant, whether an entity controls stablecoins or keys, who executes conversion, where customers and merchants are based, and which provider holds fiat funds.

Use these questions to identify what your adviser must assess for each entity and transaction step.

## Compare Costa Rica and Panama using the same facts

If Costa Rica and Panama are on your shortlist, give each adviser the same completed flow. Ask for a dated, primary source behind every statement about legal scope, registration, licensing, local presence, customer access, capital, fees or timing.

Compare the candidates in a separate table with these fields:

- activities and assets assessed;
- legal entity that would perform each activity;
- incorporation, registration and licence or authorisation requirements, kept separate;
- target markets covered by the analysis;
- custody, conversion and settlement roles;
- required people, systems, policies and evidence;
- banking, EMI, custody and liquidity-provider dependencies;
- setup and recurring costs, with sources and assumptions;
- application and operating stages, dependencies and owners;
- exclusions and questions requiring separate advice.

Leave a field blank when the source or business fact is missing. An unsupported number or broad promise makes the comparison less useful.

## Five questions to ask your adviser

1. Which activities does each entity perform in this flow, and which legal categories need to be assessed?
2. Where could customer, merchant, custody, conversion or settlement locations create additional requirements?
3. What is the distinction between incorporation, registration and licence or authorisation for each proposed route?
4. Which current primary sources support the assessment, and when were they last checked?
5. Which assumptions, provider decisions and operating capabilities must be resolved before an application or launch plan can be prepared?

For related preparation, read **“Before choosing a crypto-licensing jurisdiction: questions your adviser should answer.”**

Prepare a short summary of your proposed activities, customer countries, custody and payment flows, existing entity, budget range and intended launch window. For questions about FOL crypto-licensing services, request a free initial consultation with [Mark Paat, Sales Consultant, Associate](https://gofaizen-sherle.com/about/mark-paat), at [mark.paat@gofaizen-sherle.com](mailto:mark.paat@gofaizen-sherle.com).

[Visit the FOL crypto-licensing page](https://fastoffshorelicenses.com/crypto-license/) to explore the service and prepare your enquiry.

## Related FOL resources

- [Questions to ask before choosing a licensing jurisdiction](https://cryptolicense.fastoffshorelicenses.com/how-to-choose-an-offshore-vasp-jurisdiction-without-hidden-capital-and-staffing-surprises)
- [Prepare for a banking or EMI discussion](https://cryptolicense.fastoffshorelicenses.com/prepare-your-crypto-payment-business-for-a-banking-or-emi-discussion)