Crypto Licensing Made Simple. VASP Compliance in Every Major Jurisdiction

Cayman’s Virtual Asset (Service Providers) Act (VASPA) requires any business that issues, exchanges, transfers, administers or safeguards virtual assets to register or license with the Cayman Islands Monetary Authority (CIMA). There is a registration tier for simpler businesses and a full license for exchanges, custodians and more complex platforms.

Digital Lawyers designs Cayman structures that separate protocol, treasury and operating risks, prepare AML/CTF documentation and ensure CIMA compliance with the banks, auditors and institutional partners expect.

The BVI Virtual Assets Service Providers Act 2022 brought most crypto businesses inside a licensing regime supervised by the BVI Financial Services Commission. It covers exchange services, safekeeping and administration, issuing virtual assets and operating trading platforms.

BVI is used where founders want:
– a recognised offshore financial centre;
– flexible corporate law for token warrants, SAFEs and structured equity;
– a VASP license that can coexist with an investment fund or holding structure.

Despite the existing VASP regulatory regime, BVI remains No. 1 jurisdiction for Web3-friendly projects in 2026 and not all of them requres full VASP licensing. Reach out to our advisors for a consultation to understand whether your BVI-based project requires licensing.

Seychelles has adopted a Virtual Asset Service Providers Act and a dedicated sandbox under the Financial Services Authority (FSA) for new fintech and virtual asset business models.

For high frequency trading, derivatives or experimental models that are hard to place in mainstream hubs, Seychelles can be an option. We analyse whether your activity fits the Seychelles VASP regime or the sandbox, then design a structure that investors and compliance teams can still diligence.

Estonia now runs two parallel frameworks for crypto businesses. The FIU still issues the older VASP licenses, which remain valid only during the MiCA transition period. At the same time, Estonia has introduced the new MiCA compliant CASP regime, supervised by the Financial Supervision Authority (FSA), which will become the EU standard for crypto services.

Capital requirements now range from EUR 100,000 to EUR 250,000, depending on the services offered such as exchange, custody, transfer or ICO related services. Estonia also requires local directors, AML officers, internal control functions, audited procedures, real economic substance and detailed AML frameworks. Banks and payment institutions conduct enhanced due diligence on all VASP clients.

Until 1 July 2026, companies with an existing VASP license may continue operating, but they must upgrade to a full CASP authorisation and align their business, governance, AML and operational standards with MiCA. The shift also means stricter supervision, higher expectations for internal controls and significantly increased regulatory scrutiny by the FSA.

After 1 July 2026, the VASP regime disappears entirely. All FIU issued VASP licenses will be cancelled, and only CASP licensed entities will be permitted to provide crypto exchange, custody, transfer, issuance or other regulated digital asset services in Estonia. This transition makes Estonia one of the strictest and most institution grade EU jurisdictions for crypto operators.

Lithuania remains one of the most common European Union entry points for exchanges, custodial services and wallet operators. Registration with the Financial Crime Investigation Service requires minimum capital of EUR 125,000, a locally based AML officer, transparent ownership, and fit and proper approval for all key individuals. Despite being a registration regime rather than a full licence, Lithuania has become a preferred base for many operational crypto businesses.

With MiCA coming into force, Lithuanian registered providers will need to assess whether they should transition into a full European CASP licence and how their current structures fit with the upcoming prudential, conduct and governance standards. Some projects will be able to use Lithuania as a temporary stepping stone. Others will need to prepare for a more formal licensing process under a different EU jurisdiction.

Digital Lawyers helps founders evaluate whether Lithuania remains appropriate for their business model, structure and risk appetite. We handle the complete registration process, prepare AML and governance frameworks, and shape the corporate structure so European banks and payment providers can support ongoing operations.

Cyprus regulates crypto activity through its Crypto Asset Service Provider (CASP) regime, supervised by the Cyprus Securities and Exchange Commission. CASP registration is required for exchange, custody and other crypto asset services, and the framework already mirrors many MiCA level obligations on governance, AML, risk management and client protection. Cyprus is positioning existing CASPs to convert smoothly into full MiCA authorisations once the EU wide regime becomes fully operative.

For founders and digital asset businesses, Cyprus offers a credible EU regulatory base, access to banking and payment providers familiar with Web3 models and a predictable supervisory relationship with CySEC. CASP entities can operate across multiple crypto business lines and maintain a compliance footprint that aligns with how the European Union expects digital asset companies to be structured.

Digital Lawyers recommends Cyprus when a client needs an EU presence with a clear path toward MiCA licensing, when the business benefits from Cyprus tax and holding structures or when teams require a regulated environment that balances commercial flexibility with institutional grade oversight.

Malta regulates digital asset activity under the Virtual Financial Assets Act, which created the VFA service provider licensing framework supervised by the Malta Financial Services Authority. The regime covers trading venues, brokers, custodians, portfolio managers and other intermediaries, with licence classes that scale according to the complexity and risk profile of the services offered.

The Maltese framework is detailed and closer to a MiFID style model than many other jurisdictions. Applicants must implement structured governance, risk management, cybersecurity, financial reporting and ongoing compliance monitoring. This makes Malta attractive for institutional or infrastructure level projects that want a highly defined rulebook and a supervisor experienced in financial services oversight.

Digital Lawyers recommends Malta for clients who are ready to meet a higher compliance burden in exchange for regulatory clarity, European credibility and a licensing pathway that aligns well with what the EU is rolling out under MiCA. Malta works best for exchanges, custodians, trading firms and technology providers that need a granular and fully supervised regime.

Luxembourg requires virtual asset service providers to register with the Commission de Surveillance du Secteur Financier (CSSF) when they offer exchange or custodian wallet services on a commercial basis. The regime sits inside Luxembourg’s AML laws rather than a standalone crypto statute, but in practice the CSSF applies a high level of scrutiny, especially for institutional clients and infrastructure providers.

The jurisdiction is most relevant for custodians, tokenised fund platforms, and projects that need to integrate with the Luxembourg fund, securitisation or SPV ecosystem. Registration often connects directly with broader fund structuring, governance and depository requirements.

Digital Lawyers helps align the VASP registration with the client’s fund or structured finance setup, ensuring the crypto component fits cleanly within Luxembourg’s regulatory and institutional framework.

Liechtenstein’s Blockchain Act (TVTG) regulates “trustworthy technology” (TT) service providers, covering token issuers, token generators, custodians and trading venues. Registration with the Financial Market Authority is required, and the TVTG is unique in Europe because it defines tokens and tokenised rights as legally recognised property.

This makes Liechtenstein attractive for asset backed tokens, tokenised equity, and structured crypto products that need clear legal status attached to the underlying rights. The regime is regulatory-light compared to the European Union, while remaining credible and supervised.

Digital Lawyers uses Liechtenstein where clients need a solid property law foundation for tokenised assets and want an EU-adjacent regulator that supports innovative token structures while keeping compliance manageable.

Gibraltar operates a dedicated DLT provider licensing regime for businesses that use blockchain to store or transmit value on behalf of clients. The framework is built around nine regulatory principles and is supervised by the Gibraltar Financial Services Commission, which has become one of the most experienced crypto regulators in Europe.

The regime is designed for exchanges, custodians and trading platforms that want a specialist authority with a long track record and a clear, principles based approach rather than a rigid rule book. It offers strong credibility, but expects real governance, risk management and technical controls from applicants.

Digital Lawyers works with founders to design the group structure, prepare the regulatory documentation and risk frameworks and manage communication with the GFSC throughout the licensing process.

The United States does not offer a single federal crypto license. Instead, every crypto business is exposed to three overlapping regulatory layers.

Instead:
– The Financial Crimes Enforcement Network (FinCEN) treats many crypto businesses as money services businesses (MSBs) that must register federally and comply with Bank Secrecy Act AML rules.
– Many states treat crypto activities as money transmission, requiring money transmitter licenses (MTLs) such as the New York BitLicense and money transmission license framework.
– The Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) regulate tokens that are securities or derivatives, and enforcement has consistently treated most token offerings as securities offerings.

Digital Lawyers maps your token and platform across all three layers: FinCEN MSB status, state money transmission and securities classification. We then design structures that keep your project within acceptable risk tolerances, including use of exemptions, offshore paths and careful product design.

Canada takes a two track approach to crypto supervision. Federally, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) requires domestic and foreign virtual currency dealers to register as money services businesses. This regime mandates AML policies, reporting, ongoing monitoring and fit and proper requirements for ownership and management.

Provincial securities regulators have adopted the position that most crypto trading platforms and custodians operate a securities or derivatives marketplace. As a result, exchanges often require registration as restricted dealers and must comply with custody, disclosure, capital and investor protection rules. Token issuance, staking and yield programs may be captured as securities distribution.

Digital Lawyers assesses whether your model triggers MSB registration or provincial securities regulation, then builds the regulatory path. Where licensing is unavoidable, we prepare filings, compliance frameworks and supervisory policies. Where licensing is disproportionate, we redesign the product, jurisdiction and user onboarding model to achieve a feasible Canadian presence without creating unsustainable regulatory burdens.