Hmmm, the risks section seems dangerously sparse. I am specifically concerned with the "Regulatory Risks" section. As you dutifully mention on the third page of the prospectus the following restriction has been placed on Cypriots:
● Overseas transactions may not exceed 5,000 per month per person, and only if the transaction is sending money to a student or completing payment of an invoice related to a business.
Bitcoin subverts this unequivocally. How will you explain to regulators that once the user has withdrawn their Bitcoins there is no way to manage where they are sent? You can't. This disproves one of your points in the regulatory risk section:
By holding assets in Bitcoin outside of the legacy banking system, there is no current legal framework or technical means for the Central Bank of Cyprus or the European Central Bank to seize Neos customer deposits.
The law that would allow them to freeze (or maybe even seize) would [in this case] be that they couldn't be sure where funds are actually being sent once the coins are in the wild.
From that perspective it would not be a far to leap to think that Cyprus wouldn't necessarily make Bitcoins illegal, but they could put a temporary ban on any Cyprus-based Bitcoin business. On the flip side you say
Neo will work closely with regulators and the government to ensure the impact of our operations shall be a benefit to the economy of Cyprus, thus preventing the need to declare the use of Bitcoin as illegal.
So do you have any actual relationships with these regulators? Wouldn't it be sensible, given the enormity of your business and the source of funding, to be absolutely sure that one day xyz agency doesn't coming knocking on your doors and shut you down without notice? At least have some measure of govoernment sentiment before you dive head first into such an ambitious operation.