Frequently asked
Practical answers to the questions we hear most.
Twenty-three questions across five topics — engagement, licensing, banking, compliance, and the firm itself. If yours isn't here, raise it on the diagnostic call.
Working with us
How engagements start, how they are scoped, and how the relationship operates day-to-day.
Every engagement begins with a 45-minute scoping call with the partner who would run the matter. There is no retainer or fee for this conversation. Within seven days we deliver a written diagnostic memo with our recommendation, a fee outline, and the relevant jurisdictional analysis. If we proceed, the engagement letter is signed against a defined scope and fixed-fee package.
Licensing mandates and structured projects are scoped as fixed-fee packages with capped variations agreed in writing. Ongoing compliance retainers are monthly fixed-fee with defined scope. Pure advisory work is hourly only where the scope is genuinely open-ended (typically commercial disputes or transactional negotiations) — and even then with budget bands disclosed up-front.
A partner owns every matter end-to-end and runs every regulator interaction. Associates support — drafting, research, document preparation — but the senior relationship and the client-facing work are partner-led. This is enforced, not aspirational: we do not staff matters so junior that the partner is invisible.
Legal professional privilege is structured into every engagement. Where the matter spans multiple jurisdictions, we map the privilege rules of each and structure communications and document handling accordingly. For sensitive matters — regulatory enforcement, internal investigations, transactional pre-completion — we use dedicated privileged channels and document-management protocols. Privilege is a constraint we design around, not an afterthought.
Our smallest engagements (diagnostic memos, single-jurisdiction restructurings) start around EUR 8K. Most licensing mandates land between EUR 40K and EUR 180K depending on jurisdiction, complexity, and integration with banking and compliance. Multi-jurisdictional or enforcement-defence engagements can scale into mid-six figures. We do not work below a meaningful complexity threshold — pure incorporation work is not a useful fit.
Licensing
The pre-application, application, and post-grant lifecycle across the jurisdictions we cover.
Direct desk coverage in Singapore, Vietnam (Ho Chi Minh), Hong Kong, UAE (Dubai), Lithuania, Estonia, Malta, Cyprus, Mauritius, Labuan, Curaçao, Anjouan, Philippines, Seychelles, and Vanuatu. Through a curated network of local counsel, we deliver effectively in another 30+ jurisdictions including the UK, Switzerland, Liechtenstein, Cayman, BVI, Bermuda, and selected US states.
It depends heavily on the jurisdiction and the operator's readiness. Offshore licences (Anjouan, Curaçao, Vanuatu, SVG-equivalents) typically deliver in 4—14 weeks. Mid-tier regimes (Labuan, Lithuania, Mauritius) run 3—7 months. Tier-1 onshore licences (Singapore MAS, Hong Kong SFC, UAE VARA, Malta MGA) take 4—15 months. Most of the variance is on the operator side, not the regulator side.
No firm can. What we can do — and routinely deliver — is to avoid the regulator-side delays that come from a poorly prepared dossier. A clean application clears the regulator at the bottom of the published range; a messy application clears at the top, after multiple rounds of RFIs. The difference is often 6—12 months of elapsed time.
Refusals are uncommon when we run the file from the start — across our active book the first-pass approval rate sits around 94%. Where a refusal occurs, the options are: (1) appeal the decision within the regulator's review framework, where the grounds are procedural or evidentiary; (2) restructure and re-file, where the underlying issue is corporate, capital, or substance; or (3) pivot to a different jurisdiction where the operator profile is a better fit. We have done all three.
Yes. Roughly 40% of our practice is ongoing stewardship of licensed operators: annual filings, AML programme maintenance, MLRO support, RFI response, capital top-ups, controller changes, and regulator-led reviews. We are equally comfortable being the firm of record from day one or being engaged at month thirty-six when an issue surfaces.
Banking & operational rails
The post-licence operational layer — bank accounts, EMI relationships, settlement channels.
No, and no firm credibly can. What we deliver is: a realistic bank short-list against your business model, a dossier in the format each target bank actually wants, an attended introduction to the right institutional contact, and live support through underwriting. Our historic onboarding success rate where we lead the introduction is approximately 87%.
Operating accounts in EMIs and tier-2/3 banks across Lithuania, Estonia, Switzerland, Liechtenstein, and Singapore are realistic for properly licensed VASPs. Tier-1 universal banks remain selective but are accessible at scale — we have placed VASPs into BNY, Standard Chartered, and DBS, but each requires substance, capital, operating history, and a properly structured introduction.
Typically 6—14 weeks from first introduction to operational account. EMI onboarding is generally faster (3—8 weeks). Tier-1 correspondent relationships for regulated payment institutions take longer (12—20 weeks) due to deeper risk review. Operating in parallel — engaging multiple potential providers simultaneously — is the realistic strategy.
Triage immediately. Step one: obtain the reason in writing and assess reversibility (most are not reversible once the decision is taken). Step two: open parallel relationships at alternative providers, prioritising continuity of operations, before the existing account ages out. Step three: address the underlying trigger so the same pattern does not repeat at the replacement bank.
AML & ongoing compliance
The day-to-day stewardship that keeps a licence usable.
Yes — permanent placements (you hire them), interim cover (we second one), and co-MLRO support (we sit behind your in-house). All MLROs we place are jurisdiction-credentialed and carry professional indemnity. We do not offer rubber-stamp or nominee arrangements.
Blockchain monitoring: Chainalysis, Elliptic, TRM Labs, Coinfirm, Crystal. Customer / sanctions screening: ComplyAdvantage, Refinitiv World-Check, Sumsub, Onfido, Sanction Scanner. We are tool-agnostic — selection is driven by your business model, regulator expectations, and integration constraints.
Monthly fixed-fee retainers typically cover: periodic policy updates, MLRO support or cover, RFI response, regulator interfacing, alert-triage second-line review, quarterly and annual return preparation, external-audit support, and proactive horizon-scanning briefings. Out-of-scope work — major restructures, enforcement defence, M&A regulatory work — is scoped separately.
Across the last three years of external AML audits on programmes we deployed from scratch, the average finding count at first audit is under two, with zero critical findings. The recurring medium-severity findings concern alert-triage backlog and documentation gaps in customer-risk re-rating — both addressable in routine remediation.
About the firm
How we are structured, where we operate from, and what we will not work on.
GSS Legal operates two Southeast Asia desks — Singapore and Ho Chi Minh — as part of the wider Gofaizen & Sherle network, which holds additional offices in Tallinn, Vilnius, Warsaw, Limassol, and Dubai. Engagement letters are issued from the office best matched to the matter; the partner is the same regardless.
Gofaizen & Sherle entities are regulated as legal and consulting practices in each jurisdiction where they operate. The licensing and compliance work we do for clients sits within the scope of those regulated practices. Where formal local-bar admission is required for filings (some courts, certain regulator-facing acts), we work alongside or instruct admitted local counsel.
We do not work on retail consumer-finance applications, pure tax-arbitrage structures with no operational substance, mandates premised on resisting legitimate regulator requests, or matters that would require us to represent operators serving sanctioned jurisdictions. We also decline mandates where we are not the right fit on competence grounds, and refer onward openly when that is the honest answer.
Conflict-clearance runs against every new engagement before we accept the matter. Where a potential conflict exists with an existing client, we disclose it openly and either decline the new engagement, decline the existing if appropriate, or — in narrow circumstances and only with both clients' written consent — establish information barriers. Conflicts are a constraint we respect, not navigate around.
Ready when you are
Tell us where
Tell us where
you want to
operate.
Forty-five minutes with a partner. Jurisdiction memo within seven days. No retainer required to start.
45 min
First call with a partner.
No retainer required.
No retainer required.