VASP License -Custody
VASP license for providing custody and safekeeping of virtual assets including private key management, cold/hot wallet infrastructure, and client asset segregation.
Virtual Assets Service Providers Act 2022
Capital Required
FSC risk-based assessment, typically USD 50,000-250,000
Timeline
4-6 months
Fees
USD 10,000 application + USD 15,000 registration + USD 5,000-15,000 annual
Regulatory Body
BVI Financial Services Commission (FSC)
Legislative Framework
Virtual Assets Service Providers Act 2022 (VASPA)
Last updated: June 2025
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
Prepare comprehensive custody policy covering client agreements, asset segregation, key management, and liability frameworks.
Establish custody infrastructure with multi-signature wallets or institutional custody arrangements with independent verification.
Develop and document disaster recovery and business continuity procedures with annual testing protocols.
Submit VASP license application to FSC including custody policy, infrastructure documentation, and capitalization evidence.
Provide detailed custody procedures, key management documentation, insurance certificates, and third-party security audit reports.
Engage with FSC through assessment period for clarifications on custody safeguards and operational controls.
Obtain FSC VASP license registration and begin client custody services under regulatory supervision.
Expected Total Timeline
4-6 months
Ongoing Obligations
After obtaining your VASP License -Custody, these are the continuing compliance requirements you must maintain.
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).
Cost Summary
Capital Requirement
FSC risk-based assessment, typically USD 50,000-250,000
Application & Licensing Fees
USD 10,000 application + USD 15,000 registration + USD 5,000-15,000 annual
Jurisdiction Setup Cost
$15,000-$40,000
Annual: $15,000-$35,000
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