SVG FSA | New VASP Application Requirements
The Financial Services Authority of Saint Vincent & the Grenadines has issued updated requirements for Virtual Asset Business (VAB) applications under the Virtual Asset Business Act, 2022.
Applicants are now required to submit comprehensive documentation across the following areas:
📋 Business Model & Activities — full description of all current and proposed virtual asset activities, including exchange, transfer, custody, brokerage, and technology/platform services
🏢 Legal Entity & Group Structure — full corporate structure, parent/subsidiary entities, jurisdictions of operation, and all existing regulatory licences globally
👤 Ownership, Governance & Control — identification of all directors, senior management, and UBOs, plus governance and oversight arrangements
💻 Technology & Platform Infrastructure — platform/software descriptions, third-party providers, cybersecurity controls, and incident response frameworks
🔐 Custody & Asset Control — clarification on whether client assets are held at any stage, key management arrangements (MPC, multi-sig, etc.), and asset safeguarding measures
🛡️ AML/CFT Framework — CDD/KYC procedures, transaction monitoring, suspicious transaction reporting, FATF Travel Rule compliance, blockchain analytics tools, and FIU reporting arrangements
🌍 Customer Base & Jurisdictions — client type breakdown, jurisdictions served, and high-risk jurisdiction restrictions
🤝 Outsourcing & Third-Party Arrangements — details of all outsourcing, copies of agreements, and evidence of retained oversight
💰 Financial Resources & Operational Capacity — evidence of capital, financial projections, and risk management framework
🏠 Physical Presence in SVG — details of local offices, personnel, local directors, compliance officer, and operational staff
⚠️ Notably, the FSA is now explicitly requiring applicants to demonstrate on-shore physical substance within Saint Vincent & the Grenadines — including local directors, a compliance officer, and operational staff. This marks a significant shift from earlier application stages where no such substance requirements were in place.
This is now the second occasion on which the SVG FSA has revised its requirements and introduced new stages for applicants already in the pipeline — while no virtual asset business licences have been granted to date.
We are monitoring developments and will provide further updates as the regulatory framework continues to evolve.
