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VASP Registration/Notification Requirements

Further to the commencement order that brought the Virtual Asset (Service Providers) Law, 2020 (“the VASP Law”) into effect, the opening of registration or notification for entities wishing to provide virtual asset services came into effect on 31 October 2020.

The regulatory framework for the VASP Law will be implemented in two phases. Phase one focuses on anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) compliance, supervision and enforcement, and other key areas of risk. Under phase one, entities engaged in or wishing to engage in virtual asset services must be registered with the Authority under the VASP Law. Entities engaged in or wishing to engage in virtual asset services, already subject to the Authority’s supervision under another regulatory law, must notify (in the case of licensees) or register with (in the case of registrants) the Authority under the VASP Law. Phase two refers to the licensing and virtual asset issuance approval process that will begin when the appropriate clauses and aspects of the VASP Law come into effect.

Phase one (registration or notification) targets three groups:

  1. Entities wishing to perform virtual asset services for the first time (“New Market Entrants”);
  2. Entities providing virtual asset services prior to the commencement of the VASP Law (“Pre-Existing Service Providers”); and
  3. Existing Authority licensees that provide or propose to provide virtual asset services (“Other Authorized Entities”).

Registration or notification can be done through the VASP Application Form on the Authority’s REEFS online platform. As part of the registration or notification process, entities are also required to complete an AML/CFT form which is also available on REEFS. For further details, see our list of FAQssupervisory circular or The Anchor