El Salvador flag beside scales of justice and a digital shield with connected asset symbols, illustrating DASP licensing and compliance.

DASP License in El Salvador

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Gofaizen & Sherle helps exchanges, custodians and other digital asset service providers (DASPs) prepare their corporate structure, application documents and compliance framework for National Commission of Digital Assets (CNAD) registration. The engagement connects your proposed services with the permissions and operating arrangements they require. The regulator decides whether to authorize the business.

Service Snapshot

ParameterDetails
AuthorityNational Commission of Digital Assets (CNAD)
Regulatory outputDefinitive registration and authorization to operate
Foreign corporate applicantsSalvadoran company or a branch of a foreign company registered in El Salvador 
Government chargesInitial registration and annual renewal fees, separate from professional fees
Review stagePublished maximum of 20 business days for definitive application evaluation
Gofaizen & Sherle service priceQuoted for the agreed scope

Is This the Right Fit for Your Business?

This route suits businesses providing covered digital asset services with a Salvadoran connection. The official registration guidance includes locally domiciled providers and foreign businesses actively marketing to potential clients in the country.

Exchanges, custody businesses and trading platforms should assess registration before launch. Software-only providers, proprietary investment vehicles and token issuers need a role-specific assessment. Incorporation alone does not authorize regulated services or grant access to overseas customer markets.

Which Regulatory Route Does Your Project Need?

Your planned activities determine which registration or approval you need. Providing services to customers, issuing tokens and certifying offerings have different requirements.

Your planned activityRegistration or approval neededWhat it covers
Exchange digital assets, hold them for customers or operate a trading platformDASP registration with CNADThe services approved in your application. It does not automatically authorise a token offering.
Exchange Bitcoin, hold it for customers or process Bitcoin paymentsBitcoin Service Provider (BSP) registration with BCR, El Salvador’s Central Reserve BankBitcoin services. Additional DASP requirements may apply depending on the business model.
Issue your own tokens to investorsIssuer registration and the applicable public or private offering procedure with CNADYour role as an issuer and the relevant offering. Providing services to other businesses requires a separate assessment.
Structure or market token offerings for clientsDASP registration with CNAD covering those servicesYour work as a structurer or marketer. The client’s issuer registration and offering requirements remain separate.
Assess token offerings and prepare certification reportsCertifier registration with CNADReviewing offering information and reporting on compliance. It does not authorise exchange or custody services.
Issue a stablecoinApplicable issuer and stablecoin offering approvals from CNADIssuing the stablecoin. DASP registration alone does not approve its issuance.
Offer trading in an existing stablecoinDASP registration with CNAD and verification of the stablecoin’s trading eligibilityTrading within your approved service scope. It does not authorise you to issue the stablecoin.

A project combining these activities may need several registrations or approvals. Brazil’s DASP regime, EU CASP authorisation and VASP registration elsewhere do not replace the permissions required in El Salvador.

Which Digital Asset Services Are Covered?

Article 19 of the Digital Assets Issuance Law covers:

  • Exchange against fiat, equivalent money or other digital assets
  • Trading platforms for digital assets or their derivatives
  • Risk and price evaluation and subscription to issuances
  • Placement on platforms or wallets
  • Promotion, structuring and management of digital-asset investment products
  • Third-party transfers, custody and administration
  • Receipt and transmission of orders, and execution of derivative orders

The application must identify the services actually proposed. Token creation alone does not establish a provider role. Securities exposure, fiat payments and client-money arrangements require separate analysis.

What Will Gofaizen & Sherle Handle?

G&S provides regulatory consulting and application support tailored to your business:

  • Assess the regulatory perimeter and company or branch structure
  • Organize corporate records, ownership information and the business plan
  • Prepare governance, customer-service and AML/CFT documentation
  • Coordinate cybersecurity and custody documentation with your technical team
  • Support filing, regulatory correspondence and document revisions
  • Define post-registration compliance work within the engagement

You provide accurate information, fund the business and implement operating controls. Technology vendors deliver their systems. Local professionals handle assigned corporate formalities. Regulators and account providers make their own decisions.

What Does the Engagement Cost?

Gofaizen & Sherle provides an individual quote based on the work your business needs.

EngagementWork Priced in the ProposalWhat Affects Preparation Time
New DASP applicationCompany or branch setup, application documents, AML policies and CNAD filing supportAvailability of corporate documents, staffing and platform readiness
Changes to an existing businessReview of existing documents, correction of gaps and support for changes to registered servicesMissing documentation and the extent of operational changes
Ongoing compliance supportAgreed policy updates, corporate filings and regulatory supportFrequency of recurring tasks and applicable deadlines

The proposal specifies which services are included, their price and the preparation schedule. CNAD review is a separate stage and is not included in the preparation period.

Government registration and annual renewal fees are separate from G&S service fees. The applicable government charges are confirmed before payment.

Translations, notarisation, local staffing, technology, office and accounting costs should be budgeted separately unless expressly included in the quote.

Who Can Discuss Your Project?

Maksim Gasanbekov
Maksim Gasanbekov
Partner, Head of Sales (Crypto and Blockchain)

How Does the Registration Process Work?

Step 1 Assessment. Gofaizen & Sherle maps services, assets, customers and transaction flows.
Step 2 Preparation. The client and project team assemble corporate, operational and compliance evidence.
Step 3 Pre-registration. The regulator assesses the proposed activity and may request additional information before issuing an objection or no objection.
Step 4 Definitive filing. Gofaizen & Sherle supports the required digital and physical submission.
Step 5 Decision and registration. Following a favorable decision and fee payment, the authority issues registration and authorization, then notifies UIF.

A preliminary no objection does not authorize operations. These stages follow the published registration procedure.

What Should You Prepare for the Assessment?

Provide:

  • shareholder
  • UBO and director details
  • existing corporate records
  • supported assets
  • target countries
  • expected volumes
  • funding evidence
  • transaction-flow diagrams.

Include your custody model, platform status, banking needs, business plan and existing policies.

Identify gaps in staffing, customer support and cybersecurity early. The dossier must demonstrate operating capability, rather than rely on a future development plan.

How Long Does Preparation and Review Take?

Company formation, document preparation and technical implementation have project-specific durations. Pre-registration and responses to questions add separate dependencies.

The CNAD annual report, pages 56–57, describes up to 20 business days for definitive evaluation and payment within 10 days after a favorable decision. Requests for missing information have separate deadlines. These are individual stages, not a promised launch date. Banking follows its own assessment.

What Regulatory Framework Applies?

The Digital Assets Issuance Law, known as LEAD, establishes the provider regime. Article 18 addresses registration, Article 19 identifies services, Article 20 sets application requirements, and Article 21 governs provider obligations. The provider regulations develop operational standards. The official legal framework library also identifies separate rules for issuers, offerings and stablecoins.

Your authorization must match the business actually operated. Adding services, assets or a different commercial role requires a fresh assessment of the applicable requirements. Provider registration does not replace issuer or offering approvals.

Regulatory AspectCurrent Status
Application routePre-registration followed by definitive filing remains published
Supervisory modelOngoing monitoring and risk-based supervision
Provider verificationCheck the entity and authorized scope in the official public register

What Obligations Continue After Registration?

Registered companies must maintain:

  • Corporate compliance: Renew business registration, hold annual shareholders’ meetings, appoint an external auditor and, where applicable, a fiscal auditor. Maintain a local tax and notification address.
  • Dedicated Compliance Officers: Appoint principal and alternate officers who cannot hold the same position at other companies.
  • AML controls: Maintain customer checks, transaction monitoring, records and reporting. Approve and document annual compliance and training plans, and train staff.
  • Local Data Protection Officer: Appoint a local officer to oversee personal data protection compliance.
  • Regulatory compliance: Complete DASP renewal in the first three months of each year and maintain a local regulatory contact.
  • Operational safeguards: Protect customer assets, maintain cybersecurity, handle complaints, prevent market manipulation and report service prices and charges quarterly.

Gofaizen & Sherle supports filings, renewals, accounting, policy updates, training and local representation, and helps arrange Dedicated Compliance Officers and a Local Data Protection Officer.

How Does Gofaizen & Sherle Support Bank Account Applications?

Gofaizen & Sherle helps prepare your application for a bank, electronic money institution (EMI) or payment service provider (PSP), including:

  • Ownership details and evidence of source of funds and wealth.
  • Customer countries, counterparties and expected transaction volumes.
  • AML controls and a clear distinction between company funds and customer payment flows.

For international operations, provider selection must account for supported countries, currencies and transfers. DASP registration does not guarantee account approval. Payment services may require additional permissions.

What Tax Benefits Can Apply?

Under Article 36 of the Digital Assets Issuance Law, qualifying digital asset activities benefit from:

  • Tax exemptions on digital assets: Their nominal value, returns and income, including capital gains or ordinary income from sales and other transfers.
  • Business tax exemptions: Registered DASPs, issuers and certifiers receive exemptions from income tax, VAT and municipal taxes on qualifying activities, together with relief from corresponding withholding obligations.
  • Shareholder benefits: Exemptions extend to profits or dividends arising from those activities.

For DASPs, eligibility begins upon notification of definitive registration. These benefits do not cover every company activity. Article 36 excludes exchanges of digital assets for goods or services outside Article 19. Non-digital income and shareholders’ tax positions require individual assessment.

Frequently Asked Questions

Who needs a DASP license?

Businesses providing covered digital asset services in El Salvador, including relevant foreign providers targeting local clients. Registration authorises only the approved services.

How does DASP registration differ from BSP registration?

DASP registration concerns covered digital asset services under CNAD. BSP registration concerns Bitcoin services under BCR. A business may need both, depending on its activities.

Can a foreign company apply?

Yes, but it must first establish a company or register a branch in El Salvador. An overseas company alone is not sufficient for DASP registration.

What documents and AML arrangements are required?

Prepare corporate and ownership records, a business plan, service descriptions and evidence of operational readiness. The application must also address AML controls and principal and alternate compliance-officer appointments.

What government fees should we budget for?

Initial registration and annual renewal fees are separate from G&S service fees. The applicable amounts are confirmed before payment.

When can the business start operating?

After definitive registration and authorisation, once applicable operating requirements are met. Pre-registration does not permit launch. The published 20-business-day review period covers definitive application evaluation, not the entire setup process.

Can a custody business register?

Yes. Third-party custody is a covered service. Applicants must demonstrate appropriate safeguards for customer assets.

Does registration guarantee a bank account?

No. Banks, EMIs and PSPs independently assess ownership, funding, customer markets, transaction flows and AML controls.

Is all company income tax-exempt?

No. Article 36 provides exemptions for qualifying digital asset activities. Other income requires separate tax analysis.

Does issuing tokens automatically require DASP registration?

No. Issuer and offering requirements are assessed separately. DASP registration may also be needed if the business provides covered services.

Mark Gofaizen
Mark Gofaizen
Senior Partner, Head of Consulting
Maksim Gasanbekov
Maksim Gasanbekov
Partner, Head of Sales (Crypto and Blockchain)
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