Guideline 3.1.5
Guideline 3.1.5(iii) - App Completeness: Cryptocurrency Exchange Services Licensing Information Required
Our Take
This is a comprehensive compliance review triggered by expanding your app's availability to 80+ new countries/regions. Apple requires detailed documentation proving you have proper cryptocurrency exchange licensing for every territory where your app is available. This is not a rejection of your app's functionality, but rather Apple's due diligence process for financial services compliance.
The extensive questionnaire indicates this is a manual review by Apple's specialized financial services team, not an automated rejection. The root cause is that cryptocurrency exchange services are heavily regulated globally, and Apple needs to verify your legal compliance before allowing distribution in each jurisdiction.
The fastest path to approval is providing complete, organized documentation that demonstrates either: (1) you have proper licensing in each country, or (2) you partner with licensed third-party exchanges that handle compliance. Apple is essentially asking you to prove your business model is legally compliant across all territories.
Resolution Guide
Audit Your Exchange Services
Clearly define what constitutes "exchange services" in your app. Document whether you facilitate direct crypto-to-crypto trades, fiat-to-crypto purchases, peer-to-peer transactions, or simply display market data.
Choose Your Compliance Strategy
Option A: Direct licensing (you hold licenses) - Compile all regulatory documentation
Option B: Third-party partnership (recommended) - Document your API partnerships with licensed exchanges
Prepare Country-Specific Documentation
Create a comprehensive spreadsheet listing each country, your licensing status, and regulatory compliance approach. Include government website links where applicable.
Address AML/KYC Procedures
Document your anti-money laundering and Know Your Customer verification processes, including identity verification, transaction monitoring, and reporting procedures.
Submit Organized Response Package
Provide a clear, structured response addressing each bullet point in Apple's request. Include executive summary, detailed documentation, and specific country restrictions if applicable.
Consider Geographic Restrictions
If licensing gaps exist, proactively restrict your app's availability in non-compliant territories to expedite approval in covered regions.
Prevention
Example Rejection Email
Before & After
App available in 80+ countries without documented cryptocurrency exchange licensing compliance verification.
Comprehensive documentation package submitted proving either direct licensing or third-party partnership compliance for each territory.
What changed: Apple requires regulatory compliance verification before allowing financial services distribution globally.
Generic statement that app 'follows all applicable laws' without specific licensing documentation.
Country-by-country compliance matrix with government website links, license numbers, and partnership agreements.
What changed: Apple needs specific, verifiable documentation rather than general compliance statements.
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