The Vanuatu Financial Services Commission published a public notice on the Virtual Asset Service Providers Act No. 3 of 2025, outlining the new licensing and supervisory framework for virtual asset service providers, initial token offerings and fintech sandbox activity in Vanuatu. The Act introduces five VASP licence classes covering exchange between virtual assets and fiat or between virtual assets (Class D), transfers (Class D.1), safekeeping or control of virtual assets (Class D.2), financial business related to an issuer’s offer and sale of virtual assets including initial token offerings (Class D.3), and bank-operated exchange and custody activity (Class D.4). Applications for Classes D, D.1 and D.2 must be made in the prescribed form with the relevant fee, identify any connected agent, and include intended services, evidence of physical presence in Vanuatu, beneficial ownership and source of funds information, manager details, and any further information required by regulations, with verification as required by the Commissioner. Class D.3 applications are subject to separate requirements, including a white paper and legal opinion from an expert virtual assets lawyer, an approval letter from a VASP licensee in or outside Vanuatu, AML/CFT policies and measures, UBO and KYC information, and proof of two years’ experience in the business of initial token offerings. Fintech Sandbox Utility participation also requires Commissioner approval, with eligible activities listed alongside products falling under licences A, B and C of the Financial Dealers Licensing Act. Manager and director appointments require VFSC approval against fit and proper criteria and local substance conditions, including at least one manager and at least one director residing in Vanuatu for 12 consecutive months, with experience thresholds of at least five years for managers and at least two years for directors. The fee schedule includes VT 200,000 fees for changes or replacements of managers, directors and CTOs, and a VT 200,000 fintech sandbox application fee, with annual fees payable on each licence anniversary for renewal and continued validity; application forms and detailed requirements are referenced in VFSC guidelines available on its website.
Vanuatu Financial Services Commission 2025-05-13
Vanuatu Financial Services Commission sets out licence classes and application requirements under the new Virtual Asset Service Providers Act
The Vanuatu Financial Services Commission issued a notice on the Virtual Asset Service Providers Act No. 3 of 2025, detailing a new licensing and supervisory framework for virtual asset service providers, initial token offerings, and fintech sandbox activities. The Act introduces five VASP licence classes with specific application requirements, including evidence of physical presence, beneficial ownership, AML/CFT measures, manager and director approval criteria, and associated fees.