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Crypto & Web3

VASP - Virtual Asset Service Provider

The FATF term for any business providing virtual-asset services - exchange, transfer, custody, issuance, financial services around an ICO - and the foundation of global crypto-AML regulation.

Also known asVirtual Asset Service Provider

FATF definition

A Virtual Asset Service Provider (VASP), per FATF, is any natural or legal person who, as a business, conducts one or more of the following activities on behalf of another natural or legal person: exchange between virtual assets and fiat or other virtual assets; transfer of virtual assets; custody / administration of virtual assets; participation in and provision of financial services related to an issuer's offer or sale of a virtual asset.

VASP vs CASP

The FATF VASP definition is the global template. The EU adopted a structurally similar but more elaborate concept - the CASP - under MiCA. In jurisdictions that have not transposed MiCA (most non-EU), the operative term remains VASP.

Core obligations

  • Registration or licensing with the relevant national authority.
  • Full AML/CFT programme - CDD, transaction monitoring, sanctions screening, SAR/STOR filing.
  • Compliance with the Travel Rule.
  • Maintain on-chain market-abuse surveillance (where venues are involved).

Common pitfalls

The VASP designation is activity-based, not entity-based - a software company can become a VASP by introducing a custody feature. The 2023 FATF mutual-evaluation cycle has documented widespread under-registration in nominally regulated jurisdictions.