Compliance
The controls below are not a marketing position. They are the conditions on which this service is able to hold a bank account and be taken seriously by anyone it deals with, and they are applied to every client without exception.
Our regulatory position, stated plainly
P2P Broker connects people to each other. We are not a registered crypto-asset service provider, we do not describe ourselves as one, and we are not currently supervised as one. We do not hold, escrow or transmit client money or crypto-assets at any point, which is what keeps us outside that requirement. We also do not work with any licensed provider at present: every exchange settles directly between two individuals whose identities we have both verified.
Where we are, and where we are going
The introductions are made today by two named individuals, while we find out whether there is a market for this. The website itself is run by a technology company, named in the footer, which provides the software and is responsible for the security of your data — it takes no part in any exchange and quotes no prices. Nobody involved is a registered crypto-asset service provider. A dedicated Montenegrin company holding its own registration is the intended end state. Until it exists, the service is operated on a non-profit basis: the margin shown on the calculator belongs to the person on the other side of the exchange, and this service takes nothing out of it. We would rather tell you that than let a professional-looking website imply a licence we do not hold — and we already run the full anti-money-laundering programme described below, to the standard expected of a registered firm.
What that means in practice
Identity verification from the first euro
Montenegrin law requires identification above €1,000. We apply it at every amount. A threshold is also an instruction on how to structure around it, and we would rather not publish one.
A named Money Laundering Reporting Officer
A real person with the authority to refuse or exit any client relationship, who cannot be overruled on that decision or on the decision to make a report, and who has direct access to the board.
Sanctions and PEP screening
Against the UN, EU, OFAC, UK OFSI and Montenegrin national lists, at onboarding and again before every introduction. Every result recorded, including the negative ones.
Source of funds above €15,000
Documented and evidenced, with written sign-off. We assess whether the explanation is plausible, not merely whether a document was supplied.
Five-year record keeping
Client files, screening results, decisions and communications are retained for five years, encrypted, with every access logged against a named individual.
Annual independent review
The programme is reviewed by someone who did not build it, and the findings go to the board.
Why we cannot accept EU residents
The European Union's transitional arrangements for crypto-asset service providers ended on 1 July 2026, with no extension. Providing crypto-asset services to a client resident in the EU without authorisation under that framework is a breach regardless of where the provider itself is established. We therefore restrict access by location, ask you to confirm your residence, verify it during onboarding, and exclude EU and EEA residents in our terms.
We are aware that a location check can be circumvented. That is precisely why residence is also declared by you and then verified against documents during onboarding, rather than being inferred from your connection alone. Please do not attempt to work around this — if it emerges later, the introduction will be withdrawn and any relationship ended.
Documents available on request
Our AML/CFT policy and onboarding procedure are provided in full to banks, partner providers and supervisory authorities on request. If you are a counterparty conducting due diligence on us, please get in touch.