Seychelles VASP – Introduction of Legislative Framework

    7 min read
    By Tuendi Ltd
    Seychelles VASP – Introduction of Legislative Framework

    The Seychelles Financial Services Authority (FSA) has developed a new legislative framework for Virtual Asset Service Providers (VASPs), following a National Risk Assessment that identified significant financial crime risks associated with unregulated virtual asset activities.

    Background

    The framework aligns Seychelles with international standards, particularly FATF Recommendation 15 (on new technologies) and ESAAMLG requirements. This regulatory initiative aims to balance innovation with financial crime risk mitigation.

    Key Framework Provisions

    Licensing & Registration

    Any company providing virtual asset services (wallets, exchanges, brokers, investment) in or from Seychelles must be licensed by the FSA. Promoters of ICOs and NFTs must also register.

    Prohibited Activities

    Mining facilitiesMixer/tumbler servicesUnauthorized trade names

    Substance & Governance

    At least two directors (one resident)
    Fully staffed local office
    Local board meetings
    Accessible records in country

    Financial Requirements

    Minimum paid-up capital, reserves matching client liabilities, proper insurance, and financial reporting and audit obligations.

    Cybersecurity & Controls

    Formal policies, system controls, incident reporting, audits, business continuity plans, and senior management oversight.

    AML/CFT Compliance

    Customer due diligence
    Transaction monitoring
    STR/SAR reporting
    goAML platform submissions

    Timeline

    September 2024

    VASP Act comes into force

    December 2024

    Deadline for existing entities

    Implications

    Entities operating virtual asset businesses without licenses are conducting unauthorized activities. The FSA has full supervisory powers over VASPs, with other agencies (FIU, Central Bank, police) having defined roles under the amended laws.

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