British Virgin Islands Crypto License

Local Incorporation

The VASP must be a BVI-registered company (IBC or LLC) with a local registered agent and a registered address in the BVI. The company name must be unique and meet BVI naming conventions. At least one director is required to incorporate, but at least two will be required once licensed.

As part of the incorporation and license application process, you will need to provide the following:

• Notarized copies of passports for all directors, shareholders, and ultimate beneficial owners (UBOs)

• Notarized proof of residential address for each member (e.g., utility bill or bank statement)

• Curriculum Vitae (CV) for each key person, detailing employment history, company affiliations, job title, and countries of operation

• Confirmation letter describing the intended business activity and the applicant’s background

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Directors and Management
A minimum of two directors is required post-licensing, both subject to the FSC’s fit-and-proper criteria. One director is typically expected to reside in or frequently attend to business matters in the BVI. All key individuals—including directors, senior officers, and the MLRO—must have a clean criminal record and demonstrate relevant experience.

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Authorised Representative
A BVI-authorised person or entity must be appointed to act as liaison with the Financial Services Commission (FSC). This representative—often a licensed trust or corporate services provider—handles the license application and serves as the ongoing regulatory contact.

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Capital Adequacy
While there is no legislated minimum capital, the FSC expects the paid-in capital to be proportionate to the scale and risk of the business. Exchanges and custodians should anticipate higher capital thresholds and may need to demonstrate access to liquidity sufficient to cover 6–12 months of operational costs. Proof of funds may be requested during the application process.

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AML/CFT Compliance

Clear anti-money laundering and counter-terrorist financing controls are mandatory. The company must:

• Develop and submit an AML/KYC Manual outlining internal compliance procedures

• Appoint a qualified Money Laundering Reporting Officer (MLRO) approved by the FSC

• Implement systems for customer due diligence, transaction monitoring, and suspicious activity reporting

• Maintain comprehensive recordkeeping policies

• The application must also include:

• Risk Assessment Policy

• AML Officer appointment letter

• Written policies on data security and internal controls

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Business Plan & IT Security

You must submit a comprehensive business plan detailing your virtual asset services, operational model, compliance strategy, and risk management approach. Supporting documents include:

• A Custody Services Agreement (if holding client assets)

• A detailed Information Security Policy and Cybersecurity Program

• A technology infrastructure overview, including data protection measures and protocols for managing system breaches or outages
   

Auditor and Reporting
An independent auditor, recognized by the BVI authorities, must be appointed and reported to the FSC within 14 days of license issuance. The VASP must maintain accurate accounting records and submit periodic financial reports or audited statements to demonstrate ongoing compliance.

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Physical Presence

Although not explicitly required prior to licensing, the FSC may expect some operational presence in the BVI. At least one director or senior officer may need to demonstrate availability for in-person oversight. The appointment of a BVI-authorised representative helps fulfill this local presence requirement.

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Fit-and-Proper and Transparency
All shareholders, directors, and ultimate beneficial owners (UBOs) will undergo due diligence. The FSC requires full transparency of the ownership structure. Complex or opaque ownership arrangements are discouraged and may lead to rejection. Individuals involved must possess a strong professional reputation and the financial and technical expertise necessary to operate a compliant VASP.​​