Publication date: 22.05.2025
А highly qualified specialist who combines deep expertise in two strategically important areas: the cryptocurrency industry and international corporate law. In the field of blockchain technologies and cryptocurrencies, with over five years of practical experience, he specializes in issues of unlocking cryptocurrencies, cryptographic security, tokenization of business processes, and conducting investigations related to cryptocurrency transactions.
Initial context: A client approached our law firm — a professional crypto trader actively operating with digital assets such as USDT, BTC, and ETH. His business model involved attracting private investment and managing investor funds on a fiduciary basis using proprietary trading strategies to generate profits.
Due to rapid growth in transaction volumes and plans to expand operations and engage international partners, the client needed a reliable legal framework — a comprehensive investment agreement tailored to the specifics of working with cryptocurrencies under regulatory uncertainty both in Ukraine and abroad.
KEY CHALLENGES
- Absence of unified international standards, making it necessary to adapt the contract for potential multi-jurisdictional use.
- High AML/KYC compliance risks, especially when working with large volumes and foreign investors.
- Need to balance the interests of both parties — the trader (asset manager) and the investor — while minimizing risks of conflict, misinterpretation, or fraud accusations.
AML/KYC compliance refers to a system of legal and procedural measures aimed at preventing financial crimes such as money laundering, terrorism financing, and illicit transactions in both traditional and crypto finance.
OUR APPROACH
We began with a deep analysis of the client’s business model: financial processes, investment acquisition channels, asset management methods, and the profile of potential investors. We also examined current practices in fiduciary crypto fund management in both regulated and semi-regulated jurisdictions (e.g., Singapore, Estonia, UAE, the UK).
Based on our findings, we:
✅ Developed a contract framework covering:
- subject of the agreement — transfer of crypto assets for fiduciary management;
- rules for trading, managing, recording, and returning assets;
- reporting procedures — monthly digital reports, dashboards, investor portal access.
✅ Established financial terms including:
profit sharing model (70% to the investor, 30% to the trader);
- payout schedule — monthly or upon investment term completion;
- asset conversion logic in case of market volatility.
✅ Implemented risk management clauses including:
disclaimer on profitability guarantees;
- explicit investor acknowledgment of potential losses;
- limits on exposure to high-risk financial instruments.
✅ Included provisions for early exit from the agreement by mutual consent, and outlined a dispute resolution mechanism, including international arbitration if needed.
✅ Created a secure communication strategy involving:
encrypted communication tools (Signal, ProtonMail);
- record-keeping of all correspondence (screenshots, logs);
- regular delivery of analytics and trading reports.
RESULT
As a result, the client received a comprehensive and structured investment agreement suitable for both Ukrainian and foreign investors. The agreement:
- Is tailored to crypto market realities;
- Ensures transparency and clarity in cooperation;
- Mitigates legal risks;
- Can be integrated into formal structures — e.g., tokenization of equity stakes, registration of a trading entity in the UAE or Estonia.
🔹 Working with crypto assets, looking to raise capital or launch your own crypto fund?
Reach out — we’ll deliver not just a contract, but a legal foundation for scaling your crypto business.
