Choosing the activities covered by a Seychelles VASP licence is a legal classification decision grounded in the applicant’s operating model.
Under the Seychelles FSA Virtual Asset Service Providers Act 2024, a VASP licence may cover one or more of four permissible activities:
- Virtual Asset Wallet Provider
- Virtual Asset Exchange
- Virtual Asset Broking
- Virtual Asset Investment Provider
Determining which activities apply requires a detailed assessment of the services the business will provide in practice. Relevant questions may include:
- Will the business hold or control client virtual assets, wallets or private keys?
- Will it exchange virtual assets for fiat currency or other virtual assets?
- Will it facilitate virtual asset services or transactions with third parties on behalf of clients?
- Will it provide investment management or advisory services involving virtual assets?
These questions are indicative rather than standalone legal tests. The classification ultimately depends on the statutory definitions, applicable FSA guidance and the specific facts of the proposed business model.
Technology and outsourcing arrangements also require close examination. Engaging a third-party wallet, exchange or payment provider does not automatically establish whether the business falls within or outside the licensing perimeter. The analysis should consider the contractual allocation of responsibilities, actual transaction flows, access and authorisation rights, client-facing representations, and the degree of control or discretion exercised by each party.
Defining the proposed activities at an early stage helps align the licence application, business plan, governance arrangements, compliance framework and supporting policies with the applicable regulatory requirements.
Deneo Partners can support you throughout the VASP licensing process, from initial structuring and the assessment of permissible activities to application preparation and regulatory engagement.
