Virtual asset service provider

Spec sheet // Glossary // VASP
Glossary / V / Virtual asset service provider
Glossary · AML

Virtual asset service provider

VASPAlso called cryptoasset business, crypto exchange provider

Definition

A virtual asset service provider is a business that exchanges, transfers, holds or administers virtual assets, or provides financial services for their issue or sale, on behalf of customers. The term comes from the FATF standards, which require these firms to be licensed or registered and to apply the same AML controls as banks.

VASP ACTIVITIESEXCHANGETRANSFERCUSTODY
Fig. 1 · Virtual asset service provider
FATF Recommendation 15 · Money Laundering Regulations 2017, as amended in 2019 · MiCA
Key rulesFATF Recommendation 15 · Money Laundering Regulations 2017, as amended in 2019 · MiCA · FinCEN guidance FIN-2019-G001
Applies toCryptoasset exchange providers and custodian wallet providers
RegionsGlobal · UK · EU · US
01

How it works

The FATF defines a VASP by activity, not by technology or label. Exchanging virtual assets for fiat or for other virtual assets, transferring them, safekeeping them and taking part in token issuance all count. Countries must license or register VASPs, supervise them for anti-money laundering and terrorist financing, and require customer due diligence, transaction monitoring, record keeping and suspicious activity reporting, with sender and recipient data passed on with transfers.

Each jurisdiction writes the FATF definition into its own law under its own label. The UK registers cryptoasset exchange providers and custodian wallet providers with the FCA under the Money Laundering Regulations. The EU authorises crypto-asset service providers under MiCA. In the US, FinCEN treats most VASPs as money services businesses that must register and run a Bank Secrecy Act programme. Firms that deal with a VASP check its licence or registration first.

Step 1Map activitiesCheck which services the business offers against the VASP definition.
Step 2Register or licenseObtain registration or authorisation in each country served.
Step 3Run AML controlsApply due diligence, monitoring and reporting to customers.
Step 4Apply the travel ruleSend and receive sender and recipient data with transfers.
Step 5Assess counterpartiesCheck other VASPs for licences and AML controls before dealing.
02

The rules

Global · October 2018, Interpretive Note June 2019, updated guidance October 2021FATF Recommendation 15FATF Recommendation 15 (New technologies) and its Interpretive Note, with glossary definitions of virtual asset and VASP

Requires countries to license or register VASPs, supervise them for AML and apply the full set of preventive measures, including the travel rule.

Countries, which apply it to VASPs through national law
UK · 10 January 2020Money Laundering Regulations 2017, as amended in 2019Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (SI 2019/1511)

Brought cryptoasset businesses into the Money Laundering Regulations and requires them to register with the FCA before trading. A FSMA authorisation regime under SI 2026/102 replaces it from 25 October 2027.

Cryptoasset exchange providers and custodian wallet providers
EU · 30 December 2024MiCARegulation (EU) 2023/1114 on markets in crypto-assets

Requires firms providing crypto-asset services to be authorised as CASPs, the EU's licensed form of VASP, with AML duties set by EU AML law.

Crypto-asset service providers in the EU
US · 9 May 2019FinCEN guidance FIN-2019-G001Application of FinCEN's Regulations to Certain Business Models Involving Convertible Virtual Currencies

Confirms that businesses accepting and transmitting convertible virtual currency are money transmitters, required to register as money services businesses and meet Bank Secrecy Act duties.

Exchangers, administrators and other virtual currency businesses
03

Common questions

What is the difference between a VASP and a CASP?

VASP is the FATF term used in global standards and many national laws. CASP is the term in the EU's MiCA regulation for a firm authorised to provide crypto-asset services in the EU. A CASP is a VASP, but the CASP label and licence apply only under MiCA.

Are crypto wallets VASPs?

A custodial wallet provider that holds assets or private keys for customers is a VASP. Software that lets users hold their own keys, with no provider control over the assets, is not a VASP under the FATF definition.

Do banks need to check VASP customers?

Yes. A bank serving a VASP checks its licence or registration, its AML controls and its travel rule compliance, and treats the relationship according to its risk.