Top-Tier Legal Consultation for Procuring VASP License
The regulatory landscape governing virtual asset service providers (VASPs) has undergone substantial transformation in 2025, with jurisdictions worldwide implementing increasingly sophisticated licensing frameworks that mandate comprehensive AML/CFT compliance infrastructure, governance arrangements, and prudential safeguards as prerequisites for obtaining a crypto license and commencing operations within their regulatory perimeters.
VASP License - Key Facts
A Virtual Asset Service Provider (VASP) license constitutes the formal regulatory authorization granted by a national competent authority that permits an entity to conduct specified crypto-asset activities, including virtual currency exchange services, custodial wallet provision, and transfer services, within the boundaries of a given jurisdiction’s regulatory perimeter.
The scope of authorization varies considerably across jurisdictions, with some frameworks permitting relatively expedited market entry, while others, including the comprehensive licensing structure administered by the Malta Financial Services Authority (MFSA), impose substantially more rigorous prudential and governance requirements.
The total VASP license cost encompasses not only regulatory application fees but also share capital obligations, compliance infrastructure development, and ongoing supervisory charges, with aggregate expenditure ranging from approximately EUR 50,000 in streamlined registration regimes to EUR 150,000 or more in jurisdictions demanding comprehensive substance and capital adequacy.
Regulatory authorization under VASP frameworks is mandated for entities that conduct virtual asset activities on behalf of third parties, with the scope of this requirement extending across multiple business models as defined by FATF Recommendation 15 and subsequent national transpositions.
Entities requiring VASP authorization include:
- Cryptocurrency exchanges facilitating order matching, trade execution, and asset listing services
- Exchange operators providing crypto-to-crypto and crypto-to-fiat conversion services
- Custodial wallet providers maintaining control over client private keys and digital assets
- Payment service providers processing transactions denominated in USDT, BTC, and comparable virtual assets
- OTC desks and brokerage services executing transactions on behalf of institutional or retail clients
- Tokenisation platforms where the operator manages assets or conducts operations for users
Entities typically excluded from VASP requirements:
- Projects operating exclusively on self-custody models without management of third-party funds
- Decentralised finance protocols lacking a centralised operator, although jurisdictional interpretations vary considerably
LegalBison’s regulatory specialists conduct preliminary business model assessments to determine whether a specific operational structure falls within VASP licensing requirements across target jurisdictions.
The VASP regulatory model, while rooted in FATF Recommendation 15, has been implemented through divergent national frameworks, with each jurisdiction establishing distinct capital thresholds, substance requirements, processing timelines, and banking sector receptivity that collectively determine the viability of market entry strategies.
Jurisdictional analysis requires evaluation of multiple variables, including minimum own funds obligations, local management presence mandates, and the practical availability of correspondent banking relationships for licensed operators.
The European Union’s Markets in Crypto-Assets Regulation (MiCA) introduces the CASP crypto license framework, which harmonizes authorization requirements across member states while permitting cross-border service provision through passporting mechanisms.
Seychelles
The VASP license in Seychelles operates under the Virtual Asset Service Providers Act, 2024, administered by the Financial Services Authority (FSA), which establishes a regulatory framework designed to accommodate international crypto-asset businesses seeking offshore incorporation.
Key framework characteristics:
- Processing timelines typically range from 3-6 months, subject to application completeness
- Minimum net assets and capital requirements as prescribed by the Authority based on the nature, size, and complexity of the business
- Substance requirements pursuant to the Third Schedule of the Act, including the appointment of at least one resident director and the operation of a fully manned office in Seychelles
- AML/CFT compliance obligations aligned with FATF Recommendations, including mandatory KYC/CDD procedures and transaction monitoring
- Territorial neutrality facilitating service provision to global client bases without onshore EU or US market access
Czech Republic
The VASP license in the Czech Republic has transitioned to the Crypto-Asset Service Provider (CASP) framework under the EU MiCA regulation, administered by the Czech National Bank (CNB). This regime imposes comprehensive prudential and governance standards for entities seeking European Union market presence.
The Czech authorization procedure typically concludes within 5 to 6 months from complete application submission, with AML/CFT compliance obligations aligned with MiCA and AMLD standards.
Key framework characteristics:
- Minimum capital requirements ranging from EUR 50,000 to EUR 150,000 depending on the service classification
- CNB authorization serves as the foundational pathway for EU passporting
- Detailed programme of operations and governance arrangements required
- Local substance requirements including effective management in the EU and at least one resident director
- Authorization constitutes full MiCA compliance enabling cross-border EU market access
Panama
Panama currently has no specific legislation regulating Virtual Asset Service Providers (VASPs). Crypto-asset activities are unregulated, and there is no “VASP license” issued by the Superintendency of Banks for these specific activities. Entities operating in Panama must complying with general commercial laws, but no dedicated crypto-authorization framework is currently in force.
Key framework characteristics:
- No specific VASP license available
- Unregulated status for crypto-specific activities
- General commercial registration required for business operations
- No specific regulatory capital requirements for crypto activities
Poland
The VASP framework in Poland has transitioned to the MiCA CASP regime administered by the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, or KNF), replacing the previous registration system for new applicants.
- Minimum share capital requirements apply under MiCA standards (EUR 50,000 – EUR 150,000)
- Local presence and effective management in the EU required
- Authorization enables EU market presence through passporting rights
- Comprehensive internal control mechanisms and ICT resilience (DORA) compliance required
Processing timelines typically range from 5 to 6 months, with the framework now fully aligned with CASP authorization under MiCA implementation, necessitating enhanced prudential and governance requirements for operators.
Lithuania
The crypto license in Lithuania has transitioned to the MiCA CASP framework administered by the Bank of Lithuania, shifting from the previous AML-focused registration regime overseen by the FCIS. This establishes the jurisdiction as a fully regulated European hub for cryptocurrency services with EU passporting capabilities.
The authorization procedure typically requires 5-6 months from complete application submission, contingent upon documentation comprehensiveness and regulatory caseload.
Key framework characteristics:
- Minimum share capital requirements aligned with MiCA tiers (EUR 50,000, EUR 125,000, or EUR 150,000)
- Local management and substance requirements, including resident directors
- Comprehensive internal control and risk management policies required
- Transaction monitoring systems and segregation of client funds mandatory
- LegalBison maintains established relationships with Lithuanian banking institutions, facilitating account opening procedures for licensed operators
Dubai / VARA
Key framework characteristics:
- Tiered licensing categories with capital requirements scaling by service classification
- Substantial local presence and mind-and-management requirements
- Comprehensive fit and proper assessments for beneficial owners and senior management
- Enhanced due diligence and ongoing compliance monitoring obligations
The Virtual Assets Regulatory Authority (VARA) administers Dubai’s comprehensive licensing framework, imposing rigorous prudential standards and governance requirements that position the jurisdiction for operators targeting institutional and premium international markets.
Unlike the MiCA crypto license framework applicable within EU member states, VARA authorization operates under an independent supervisory architecture with distinct capital and substance mandates, with processing timelines typically ranging from 3 to 6 months, subject to application complexity and pre-licensing consultation outcomes.
Switzerland
The Swiss Financial Market Supervisory Authority (FINMA) administers a tiered licensing framework establishing institutional-grade standards for virtual asset operators.
The FinTech license category requires minimum capital of CHF 300,000 (or 3% of public deposits) alongside comprehensive governance arrangements, while banking license pathways apply to operators exceeding deposit thresholds or providing expanded service ranges.
- FinTech license or banking license pathways depending on service scope
- Robust AML/CFT framework aligned with FATF Recommendations
- Processing timelines typically range from 3 to 6 months
- Comprehensive substance requirements, including local management presence
The regulatory architecture and established institutional banking infrastructure position Switzerland for operators seeking to establish long-term, institutionally focused crypto-asset businesses with access to sophisticated custody solutions.
Cayman Islands
The Cayman Islands Monetary Authority (CIMA) administers the Virtual Asset (Service Providers) Act (2024 Revision), which establishes a formal VASP registration and licensing regime suitable for international holding structures and multi-jurisdictional platforms.
Key framework characteristics:
- VASP registration/licensing required for entities conducting specified virtual asset activities
- Tiered authorization categories based on service classification
- AML/CFT compliance framework aligned with FATF standards
- Established infrastructure for fund structures and institutional vehicles
The developed legal and fiduciary services ecosystem supports complex corporate arrangements, with processing timelines subject to CIMA capacity and application complexity, typically extending across several months for comprehensive licensing applications.
British Virgin Islands (BVI)
The BVI Financial Services Commission administers the Virtual Assets Service Providers Act, 2022, establishing a dedicated licensing framework that balances regulatory oversight with operational flexibility for offshore virtual asset businesses.
Key framework characteristics:
- Dedicated VASP Act providing statutory licensing authority
- Requirements for at least two individual directors and an authorized representative
- AML/CFT compliance obligations under the Proceeds of Criminal Conduct Act
- Registration enables international service provision without onshore market restrictions
The jurisdiction maintains substance requirements while permitting streamlined corporate structuring, supported by an established offshore legal ecosystem that facilitates efficient entity formation and ongoing corporate governance.
Estonia
The Estonian crypto license framework is now fully aligned with the EU MiCA regulation, administered by the Financial Supervision Authority (Finantsinspektsioon). This represents a shift from the previous FIU-administered AML registration to a full financial service authorization.
The Financial Supervision Authority requires capital ranging from EUR 50,000 to EUR 150,000 depending on service categories, with processing timelines typically spanning 5 to 6 months.
- Local management board members and effective management in Estonia required
- Comprehensive business-wide risk assessment and internal audit mandatory
- Full alignment with MiCA operational and prudential standards
- Transition toward full MiCA CASP authorization is mandatory for new entrants
Comparative Overview of VASP License Requirements by Jurisdiction
The following comparative analysis presents key regulatory parameters across selected jurisdictions, enabling systematic evaluation of capital thresholds, substance mandates, and processing timelines for VASP authorization pathways.
| Jurisdiction | Min. Capital | Local Presence | Timeframe | Regulatory Status |
| Seychelles | Prescribed by Authority | Resident director & office | 3-6 months | VASP Act 2024 |
| Czech Republic | EUR 50k – 150k | Substance required | 5-6 months | EU MiCA Framework |
| Lithuania | EUR 50k – 150k | Substance required | 5-6 months | EU MiCA Framework |
| SVG | Statutory Deposit | Principal Representative | 30-90 days | VASP Act 2022 |
| Panama | None | None | N/A | Unregulated |
| Poland | EUR 50k – 150k | Substance required | 5-6 months | EU MiCA Framework |
VASP Licensing Assistance by LegalBison
LegalBison provides end-to-end VASP licensing support encompassing jurisdictional analysis, corporate structuring, AML/CFT program development, regulatory documentation preparation, application management, key personnel sourcing, and post-authorization compliance monitoring across multiple jurisdictions.
Requirements for VASP License Authorization
VASP authorization procedures mandate compliance across multiple requirement categories, each subject to regulatory scrutiny during the application assessment process.
Corporate Requirements
- Legal entity registration in the chosen jurisdiction (LLC, Ltd, AG, or equivalent)
- Registered office address with demonstrable local substance
- Organizational structure documentation and shareholder registry
Financial Requirements
- Minimum share capital ranging from EUR 50,000 to EUR 150,000 depending on service scope under MiCA Article 67 (Annex IV)
- Source of funds verification for initial capitalization
- Evidence of financial sustainability and operational reserves
Management and Beneficial Ownership
- Fit and proper assessment for directors, senior managers, and Ultimate Beneficial Owners (UBOs)
- Criminal record certificates and bankruptcy declarations
- Demonstrated professional experience in financial services, crypto-assets, or compliance functions
AML/CFT Compliance Infrastructure
- Appointment of a qualified Money Laundering Reporting Officer (MLRO)
- Internal AML/CFT policies aligned with FATF Recommendations
- KYC/CDD procedures and transaction monitoring systems
- SAR/STR reporting mechanisms
Technical and Operational Standards
- Platform security protocols and asset custody arrangements
- Cybersecurity frameworks and incident response procedures
- Record-keeping systems compliant with data retention requirements
Documentation Package
- Regulatory-grade business plan with financial projections
- Product and service descriptions within the intended scope of authorization
- Business-wide risk assessment (BWRA)
LegalBison’s cross-departmental teams assist applicants in assembling documentation packages that address each requirement category comprehensively.
VASP License Application Procedure
The VASP authorization pathway follows a structured sequence of procedural stages, each requiring specific documentation and regulatory interaction prior to progression to subsequent phases.
- Step 1: Business Model Analysis and Jurisdiction Selection
Initial assessment involves mapping the intended service offering against available regulatory frameworks to identify jurisdictions where the business model falls within the defined regulatory perimeter and authorization categories. - Step 2: Corporate Entity Establishment
Legal entity formation in the selected jurisdiction precedes regulatory application, with the organizational structure, share capital, and registered office established in accordance with local corporate law requirements. - Step 3: Compliance Infrastructure Development
AML/CFT policies, KYC/CDD procedures, transaction monitoring systems, and business-wide risk assessments must be developed and documented prior to application submission, as regulators assess operational readiness during the review process. - Step 4: Key Personnel Appointment
Appointment of fit and proper individuals to director, MLRO, and compliance officer positions, with supporting documentation including professional credentials, criminal record certificates, and CVs demonstrating relevant experience. - Step 5: Application Submission
Complete documentation packages are submitted to the relevant regulatory authority, with processing timelines typically ranging from 3 to 6 months depending on jurisdiction and application complexity. - Step 6: Regulatory Review and Q&A
Regulatory authorities may issue clarification requests or deficiency notices requiring supplementary documentation or policy amendments before final determination. - Step 7: Authorization and Operational Launch
Upon approval, post-authorization obligations commence, including supervisory reporting, ongoing compliance monitoring, and periodic regulatory filings.
Risks and Benefits of VASP Licensing
The decision to pursue VASP authorization involves weighing operational advantages against regulatory obligations and associated costs, with both dimensions requiring careful assessment during the strategic planning phase.
Benefits of VASP Licensing:
- Banking sector access: Licensed VASP status significantly improves prospects for establishing correspondent banking relationships and payment processing arrangements, as financial institutions increasingly restrict services to unlicensed crypto operators
- Market legitimacy: Regulatory authorization demonstrates compliance commitment to institutional clients, partners, and investors conducting due diligence on counterparty risk
- EU passporting potential: MiCA-authorized CASPs will obtain cross-border service provision rights across all 27 Member States under Article 65, eliminating the need for multiple national registrations
- Reduced enforcement exposure: Operating within a defined regulatory perimeter mitigates risks of supervisory action, license revocation, or criminal liability for unlicensed financial services provision
Risks and Considerations:
- Capital immobilization: Own funds requirements ranging from EUR 50,000 to EUR 150,000 under MiCA represent permanent capital that cannot be deployed for operational purposes
- Ongoing compliance costs: Post-authorization obligations, including supervisory reporting, audit requirements, and compliance staffing, create recurring operational expenses
- Regulatory change exposure: Evolving frameworks may introduce additional requirements, necessitating continuous adaptation of policies and procedures
Application rejection risk: Incomplete documentation or fit and proper assessment failures may result in application denial and associated sunk costs
FAQ
VASP authorizations are typically granted to specific legal entities and are not transferable; change of control transactions generally require regulatory notification and, in many jurisdictions, prior approval from the competent authority.
Validity periods vary by jurisdiction, with some frameworks granting indefinite authorization subject to ongoing compliance, while others mandate periodic renewal (e.g., annually in some offshore jurisdictions).
The scope of authorization depends on the service categories specified in the application; operators seeking to expand beyond their initial authorization perimeter must typically submit variation applications.
Applicants generally retain the right to reapply after addressing identified deficiencies, although some jurisdictions impose waiting periods or require demonstration of material changes to circumstances before resubmission.
