On 27 October 2026, the Financial Services Authority (FSA) of Seychelles issued Circular No. 6 of 2026, reinforcing the cross-border regulatory obligations of transitional operators under the Virtual Asset Service Providers Act, 2024.
The Circular delivers a clear message: Authorisation to operate in or from Seychelles does not automatically confer the right to provide, market, or solicit virtual asset services in other jurisdictions.
Key Regulatory Highlights
- Cross-Border Licensing: Transitional operators must assess and comply with applicable licensing, registration, and authorisation requirements in every jurisdiction where they solicit clients, advertise, or provide virtual asset services.
- Ongoing Regulatory Assessments: Cross-border compliance is a continuous obligation, not a one-off assessment at market entry.
- Regulatory Documentation: Operators must maintain records of jurisdictional assessments and foreign regulatory authorisations and make them available to the FSA upon request.
- Enforcement Exposure: Unauthorised activities in foreign jurisdictions may adversely affect fitness and propriety assessments and trigger regulatory measures, including business restrictions, suspension or revocation of licences, and rejection of pending licence applications.
- Corrective Measures: Operators must review their current cross-border activities, address identified licensing deficiencies, potentially cease activities in affected jurisdictions, and inform the FSA accordingly.
Key Takeaway: A Seychelles VASP authorisation is not a passport to operate globally. VASPs must ensure that their geographic footprint, marketing activities, and client solicitation practices align with the regulatory requirements of each relevant jurisdiction.
