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VASP compliance
Licensing readiness and ongoing compliance for virtual asset service providers under the VASP Act 2025 and the Regulations 2026, including the operational half that applications tend to leave until last.
The transitional window under the Act closes on 4 November 2026, and from that date operating without a licence is a criminal offence rather than a regulatory irregularity. A great many businesses are inside the licensing perimeter without having concluded that they are.
There are two halves to being ready. The first is the application file, which is largely a legal exercise and belongs with your advocate. The second is whether your systems, records and people would actually satisfy a supervisor who came looking. We work on the second half, alongside counsel rather than in place of them.
What this includes
- Perimeter assessment: whether your activities require a licence, and which category
- Gap analysis against the operational obligations in the Regulations
- AML and CFT programme design anchored in the Proceeds of Crime and Anti-Money Laundering Act
- Customer due diligence frameworks built for a pseudonymous environment
- Transaction monitoring design, including thresholds and typologies that produce a workable caseload
- Record keeping architecture for the seven year retention duty, including chain metadata
- Analyst training so the programme is operated by people who understand it
How it runs
We begin with a perimeter and gap assessment, which is deliberately blunt and usually uncomfortable. From there we prioritise by regulatory exposure rather than by ease, design the remediation with your team, and stay involved through implementation. Where the work touches your legal position we hand off to your advocate explicitly rather than quietly advising around the edges.
What you receive
- A written gap assessment mapped to specific obligations
- Drafted policies and procedures your team can actually operate
- Monitoring rules and escalation paths, documented
- Trained staff and a record of that training for the supervisor
Worth knowing
We do not submit applications and we do not advise on your legal obligations. Those are functions for your advocate. What we do is make sure that the operation described in the application is the operation you actually have.
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