Virtual Asset Service Provider (VASP)

Overview

The term is used in anti-money-laundering frameworks, notably by the Financial Action Task Force, to describe covered service activity involving virtual assets. Depending on facts and jurisdiction, exchanges, custodians, transfer services, brokers, and certain issuance-related providers may qualify.

A technical label such as decentralized, non-custodial, protocol, or wallet does not by itself determine regulatory status. Classification depends on the activities performed, control, business relationship, jurisdiction, and applicable law, which may differ from the FATF framework or change over time.

Organizations should obtain jurisdiction-specific legal analysis, map services and control, identify licensing or registration, customer due diligence, sanctions, recordkeeping, reporting, and transfer-information obligations, and monitor regulatory change. Outsourcing compliance functions does not necessarily transfer accountability.

A Virtual Asset Service Provider is a business that performs specified virtual-asset exchange, transfer, safekeeping, administration, or related financial services for others. VASP status follows actual services and jurisdiction, so businesses must assess activities, control, customers, licensing, AML obligations, and regulatory change.

A production treatment of Virtual Asset Service Provider (VASP) should test a business that performs specified virtual-asset exchange, transfer, safekeeping, administration, or related financial services for others within the relevant asset, decision, or service state. The Virtual Asset Service context record for business that performs specified virtual-asset exchange, transfer, and safekeeping should preserve source data, configuration or policy version, responsible actor, exception, and outcome. Review of Virtual Asset Service Provider (VASP) should determine whether safeguards addressing business that performs specified virtual-asset exchange, transfer, and safekeeping changed exposure in practice, not merely whether a document or setting existed.

Quality review for Virtual Asset Service Provider (VASP) should sample real cases involving business that performs specified virtual-asset exchange, transfer, and safekeeping, compare expected and actual outcomes, and track unresolved exceptions until remediation is independently verified.