British Virgin Islands

Key Requirements

• Demonstrate minimum capital of USD 50,000-250,000 as assessed by FSC based on asset type, storage method, and client numbers.
• Establish written custody agreements with each client specifying asset safeguarding responsibilities, liability limitations, and disputes procedures.
• Implement multi-signature wallet infrastructure or institutional custody arrangements with documented key management procedures.
• Maintain segregated client asset wallets with regular reconciliation ensuring 100% client asset accountability.
• Establish documented procedures for private key generation, storage, backup, and recovery with independent verification controls.
• Conduct annual independent security audits covering wallet infrastructure, access controls, and incident response capabilities.
• Implement comprehensive cyber insurance coverage for digital asset custody with minimum limits of USD 1,000,000+.
• Establish documented business continuity and disaster recovery procedures with annual testing and documented remediation of identified gaps.

Application Process

1. 1.Prepare comprehensive custody policy covering client agreements, asset segregation, key management, and liability frameworks.
2. 2.Establish custody infrastructure with multi-signature wallets or institutional custody arrangements with independent verification.
3. 3.Develop and document disaster recovery and business continuity procedures with annual testing protocols.
4. 4.Submit VASP license application to FSC including custody policy, infrastructure documentation, and capitalization evidence.
5. 5.Provide detailed custody procedures, key management documentation, insurance certificates, and third-party security audit reports.
6. 6.Engage with FSC through assessment period for clarifications on custody safeguards and operational controls.
7. 7.Obtain FSC VASP license registration and begin client custody services under regulatory supervision.

Ongoing Obligations

• Maintain minimum capital requirement throughout licensing period with quarterly reporting to FSC of capital position.
• Conduct monthly client asset reconciliation with documented procedures and exception resolution within 48 hours.
• Submit annual audited financial statements and custody reports detailing client assets held and reconciliation results.
• Report any custody-related incidents including unauthorized access, key compromise, or asset discrepancies to FSC within 24 hours.
• Maintain cyber insurance continuously without lapse and notify FSC of any material policy changes or coverage reductions.
• Conduct annual security audits and disaster recovery testing with documented results provided to FSC.
• Comply with FSC requests for custody documentation, client records, and operational procedures within specified timeframes (typically 5 business days).

Key Requirements

• Maintain minimum capital of USD 100,000-500,000 as risk-assessed by FSC based on transaction volume, traded asset pairs, and leverage offered.
• Establish published non-discretionary trading rules governing order matching, execution, settlement, and dispute resolution per VASPA requirements.
• Implement real-time price feeds with published order books or continuous price quotes for all trading pairs.
• Establish market surveillance program monitoring for market abuse including price manipulation, wash trading, and insider trading indicators.
• Implement order validation system including position limits, price checks, and risk controls per documented trading rules.
• Maintain segregation of client funds in separate bank/crypto accounts with monthly reconciliation and published asset backing reports.
• Establish documented procedures for member/trader admission, good standing monitoring, and account suspension/termination protocols.
• Implement comprehensive insurance coverage for exchange operations including cyber insurance, errors and omissions, and fidelity bonds.

Application Process

1. 1.Prepare comprehensive exchange rules including order types, matching procedures, settlement terms, and dispute resolution mechanisms.
2. 2.Design market surveillance system with documented monitoring procedures covering trading patterns, position accumulation, and price movements.
3. 3.Establish exchange infrastructure with documented uptime targets and backup procedures ensuring continuous 24/7 operational capability.
4. 4.Prepare capitalization plan documenting fund sources and capital maintenance throughout licensing period.
5. 5.Submit VASP license application to FSC including trading rules, surveillance procedures, and operational infrastructure documentation.
6. 6.Provide evidence of capital adequacy, market surveillance implementation, and business continuity arrangements.
7. 7.Engage with FSC for review of trading procedures, member protection safeguards, and capital maintenance plans.
8. 8.Obtain FSC VASP license and publish trading rules before accepting member registrations and commencing exchange operations.

Ongoing Obligations

• Maintain minimum capital requirement with quarterly reporting to FSC of capital position and capital adequacy calculations.
• Notify FSC of any trading rule modifications within 15 days before implementation and maintain documented trading rule compliance.
• Monitor and report suspected market abuse to FSC with documented investigation results and remediation actions within 10 days.
• Conduct monthly client fund reconciliation with independent bank/crypto asset verification and address discrepancies within 5 days.
• Maintain member/trader admission records and conduct annual good standing reviews with documented sanctions for rule violations.
• Publish monthly trading statistics including volumes, market participants, and trading pair activity demonstrating market development.
• Submit annual audited financial statements and compliance reports detailing trading activity, market surveillance findings, and regulatory compliance.

Key Requirements

• Demonstrate minimum capital adequacy as risk-assessed by FSC based on service type, client numbers, and assets under management/administration.
• Establish detailed service descriptions documenting transfer procedures, portfolio management methodologies, or advisory service scope.
• Implement client agreement templates covering service terms, fee structures, liability limitations, and dispute resolution procedures.
• Maintain client records including service agreements, transaction histories, and performance reporting for regulatory inspection purposes.
• Establish documented procedures for client asset handling including transfer authorization, settlement verification, and error correction.
• Implement AML/CFT compliance program including customer due diligence, beneficial ownership verification, and transaction monitoring.
• Conduct annual compliance audits documenting adherence to service terms, AML procedures, and client protection arrangements.
• Establish business continuity procedures ensuring service continuity during operational disruptions or key personnel departures.

Application Process

1. 1.Prepare detailed service offering documentation describing transfer, portfolio management, or advisory services and operating procedures.
2. 2.Develop client agreement templates and documented service delivery procedures.
3. 3.Establish AML/CFT compliance framework including customer due diligence and transaction monitoring procedures.
4. 4.Prepare capitalization evidence demonstrating adequate capital for proposed service scope and client base.
5. 5.Submit VASP license application to FSC including service documentation, client agreements, and AML/CFT framework.
6. 6.Provide detailed operating procedures, compliance documentation, and capital adequacy analysis.
7. 7.Engage with FSC for review of service procedures and client protection safeguards.
8. 8.Obtain FSC VASP license and commence service delivery under regulatory supervision.

Ongoing Obligations

• Maintain capital adequacy throughout licensing period with quarterly reporting to FSC of financial position.
• Submit annual compliance reports documenting AML/CFT procedures, customer transactions, and regulatory adherence.
• Notify FSC of material changes to service offerings, client base, or operating procedures within 15 days.
• Maintain client service records and make available to FSC within 5 business days upon request.
• Implement documented procedures addressing client complaints and disputes within 30-day resolution timeline.
• Conduct annual compliance audits addressing service delivery, AML/CFT compliance, and client protection safeguards.
• Report any suspicious transactions or regulatory violations to FSC immediately upon discovery.