What exactly is a VASP, anyway?

  • Cryptocurrencies
  • Standard cryptocurrency
  • Utility Tokens
  • NFTs
  • Stablecoins
  • Central bank issued digital currency
  • Centralized Exchange
  • Decentralized Exchange
  • Wallet Providers or Platforms
  • Escrow services including, but not limited to:
  • Smart contract powered services
  • Brokerage services
  • Order-book exchange services
  • Advanced trading services
  • Custody providers
  • Mining pools
  • Investment vehicles
  1. Are digital representations of value that can be digitally traded or transferred.
  2. Can be used for payment or investment purposes.
  3. Do not include digital representation of fiat currency.
  4. Do not include digital representation of securities.
  1. Can be legal or natural persons or business entities, and as a business conducts one or more of the following activities on behalf of another natural or legal person or business:
  2. Exchange between VAs and fiat currencies.
  3. Exchange between one or multiple forms of VAs.
  4. Facilitate transfers of VAs.
  5. Safekeeping and/or administration of VAs or instruments enabling control over VAs.
  6. Participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset.
The Financial Action Task Force’s 39 Member Nations
  • Most (non-fungible tokens) NFTs should be considered VAs.
  • Stablecoins should be considered VAs.
  • Central bank issued digital currencies should not be considered VAs.
  • Decentralized Exchanges should be considered VASPs.
  • Decentralized platforms or DApps are considered VASPs (so far that the relevant smart-contract developers are considered VASPs for having written code that executes operations which fall under the definition of a VASP as laid out in 2018)
  • VA escrow services are all VASPs.
  • Any platform facilitating P2P transactions between individuals is a VASP.



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