RSM Malta

Blockchain Services

Malta has cemented itself as one of the leading jurisdictions in respect to blockchain and cryptocurrencies, providing a legal framework that is driving innovation within this exciting industry.

At RSM Malta, we are eager to assist organisations through the following services:

VFA Agent Services

RSM Malta may act as a VFA Agent to your organisation in accordance with Chapter 373 of the Laws of Malta and the relevant subsidiary legislation. A VFA Agent is required to possess certain skills or competencies in order to engage in discussions with your organisation on the purposes of your Initial Coin Offerings (ICO) and to assist in performing a Financial Instruments Test to ascertain whether the underlying nature of the coin or token to be issued is a virtual financial asset, a virtual token, electronic money or a financial instrument. Such test will determine which laws and rules apply for the issue and the classification of such assets.

Acting as your VFA Agent, we will be in a position to determine whether your business plans are significant and robust whilst also guiding you on the requirements, information and disclosures that are mandated by the Malta Financial Services Authority (MFSA) through the four licence classes. We will act as the main point of contact for your organisation with the MFSA by (not limited to) creating an open dialogue, holding regular meetings, communicating proposed changes, defining and submitting annual compliance reports and much more. We will also assist in ensuring that all necessary due-diligence documentation is in place and kept up to date in accordance with the relevant anti-money laundering regulation.

Audit Services

RSM Malta may act as systems auditor for your organisation in order to recognise your Innovative Technology Arrangement (ITA) through the Malta Digital Innovation Authority (MDIA). Once certified, the ITA shall be provided with a certification and will include details on how the ITA is identified.

Certification of an ITA is awarded once a number of requirements are met, including but not limited to:

  • The ITA is fit and proper for the purpose for which it has been established;
  • The software comprising the arrangement has been reviewed by a registered systems auditor who is independent from any individual involved in the ITA.

RSM Malta posses’ personnel who are Certified Information Systems Auditors (CISAs) and may carry out both Type 1 and Type 2 systems audits as mandated by regulation.

The Type 1 audit is carried during the application process of an ITA or when deemed necessary by the MDIA, or other Lead Authority in Malta. The Type 2 audit is carried out periodically during the operational lifetime of an ITA (once certification is granted by the MDIA), or on the request of the MDIA, or other Lead Authority in Malta. During the process of conducting the audits, we will draw up a System Auditor Reasonable Assurance Report to be submitted to the MDIA. The type of audit to be carried out is dependent on whether the ITA is operative or non-operative.

Other services that we offer that may be of interest to you include but are not limited to:

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Vladimiro Comodini


Position: Partner
Contact Number: (+356) 79 846 536
Email: [email protected]

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Gordon Micallef


Position: Partner
Contact Number: (+356) 99 451 641
Email: [email protected]

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Timothy Zammit


Position: Partner 
Contact Number: (+356) 79 893 273
Email: [email protected]