Gofaizen & Sherle helps exchanges, custodians and other virtual asset businesses assess where and how they can operate. VASP licensing support starts with your activities, customer markets and company structure, then moves to application preparation and compliance setup. The first step is to identify a suitable route and the work needed before filing.
Quick Facts
Service Snapshot
What to Expect
Starting point
Business assessment and jurisdiction selection
Scope
Corporate structuring, VASP license application and compliance framework
Price basis
Agreed work, official fees and external costs
Timing
Client readiness, document preparation and authority review
Is This the Right Fit for Your Business?
An assessment is relevant if you provide virtual asset services for customers, including exchange, custody or transfers. Software-only development or investing solely for your own account does not automatically make you a VASP. However, a non-custodial label alone does not settle the question: actual control and active facilitation matter under FATF guidance.
A VASP license assessment should also identify activities needing separate treatment, such as derivatives or tokenized financial instruments. The broader crypto license guide helps place these alternatives in context.
VASP License vs. Other Licensing Routes
There is no universal “VASP license.” The appropriate route depends on the services you provide, where your customers are and the requirements your business must meet.
Route
Examples
What It Means in Practice
What to Assess
AML registration
US MSB (FinCEN), Canada MSB (FINTRAC)
Registration for AML/CFT supervision. It should not be treated as permission for every financial activity.
Whether additional permissions apply. In the US, this includes checking state-level licensing requirements.
Activity-specific licensing
Dubai (VARA)
Permission to provide the virtual asset services specified in the licence.
Permitted activities, capital, staffing and ongoing compliance obligations under the relevant VARA requirements.
EU CASP authorisation
EU national competent authorities under MiCA
Authorisation for specified crypto-asset services, with cross-border provision across the EU subject to MiCA procedures.
Whether your business needs CASP authorisation. Certain existing financial institutions can provide eligible services through the Article 60 route, as recognised in MiCA Article 59.
VASP registration or licensing in offshore jurisdictions
Seychelles, Cayman Islands
Country-specific regulatory regimes. “Offshore” describes the location, not a lighter category of permission.
The applicable offshore licensing requirements and restrictions in customer markets. For example, Cayman custody and trading platform services require a licence under CIMA’s rules.
How to Choose
Start with what customers can do through your platform and where they are located. Identify the required permissions before comparing capital, staffing, costs and launch timelines. Incorporating a company alone does not authorise it to provide regulated crypto services.
A business serving several markets may need multiple permissions. Gofaizen & Sherle can help assess the appropriate combination and define the scope of application support.
Which Virtual Asset Services Need Assessment?
Map what the business actually does before choosing a VASP license. FATF’s activity categories provide a starting point, while domestic law determines the permission.
Business Model
Activity to Assess
Exchange or OTC desk
Conversion between fiat and virtual assets, or between virtual assets
Custodial wallet
Safekeeping or administration of assets or instruments enabling control
Transfer / remittance service
Moving virtual assets for another person
Trading platform
Operating a market for customer orders, assessed under the relevant national activity definitions
Token distribution intermediary
Participation in financial services related to an issuer’s offer or sale
Issuing a token and providing services around its distribution are distinct questions. A VASP license should never be assumed to cover every digital asset product.
What Does VASP License Support Include?
Gofaizen & Sherle can support the following workstreams, with deliverables agreed for the selected route:
Assessment: activity classification, jurisdiction comparison and an application gap list.
Corporate setup: company formation and ownership or governance structuring.
Application preparation: business descriptions, corporate evidence and regulator-facing documents.
Compliance framework: AML/CFT policies, customer due diligence procedures and governance responsibilities.
Regulator communications: responses to questions and revisions to the submission.
After authorisation: compliance updates and ongoing regulatory support within the agreed engagement.
VASP license support does not replace the client’s responsibility to provide accurate evidence, appoint suitable personnel and implement operational controls.
What Determines VASP License Cost?
VASP license cost depends on service scope, entity structure and the work already completed. Compare quotations by separating these items:
Budget Component
What to Clarify
Gofaizen & Sherle professional fee
Included deliverables, revisions and exclusions
Official charges
Application, supervision and renewal fees where applicable
Third-party costs
Translations, certification, audits and external providers
Share capital and regulatory capital
Applicable minimums, payment timing and ongoing capital requirements
Operating budget
Staff, premises, technology and ongoing compliance
Required capital is a separate funding requirement, not a licensing fee. A VASP license quotation should specify whether company setup and post-authorisation work are included or separately scoped.
How Does the Application Process Work?
The VASP licensing process has five practical stages. Filing order and incorporation steps are adapted to local rules.
Step1Assess: Gofaizen & Sherle reviews the model and target markets with the client.
Step2Select: the client chooses a route after reviewing scope, obligations and dependencies.
Step3Prepare: Gofaizen & Sherle develops the agreed documentation. The client supplies evidence and implements the required setup.
Step4Submit and respond: the application is filed through the applicable channel. Gofaizen & Sherle assists with authority questions.
Step5Confirm readiness: the client checks permission scope and outstanding conditions before starting the relevant services.
The authority independently decides the VASP license application.
What Information Is Needed from the Client?
For an initial VASP license assessment, prepare:
Company documents and ownership details, including beneficial owners.
Services, customer countries and transaction-flow descriptions.
Management profiles, funding information and planned local presence.
Existing business plans, compliance policies and technology-provider arrangements.
This is an assessment checklist. The final application requirements depend on the chosen route.
How Long Does Preparation and Review Take?
There is no reliable global VASP license timeline. The overall timeline includes preparing the application documents, putting the required staff, systems and controls in place, and waiting for the regulator to assess the application. Missing ownership evidence, unresolved custody arrangements or changes to the business model can affect the schedule. Any estimate should identify its assumptions and the stages outside Gofaizen & Sherle’s control.
Which Regulations Apply?
FATF sets international AML/CFT standards. National legislation establishes registration or licensing duties and supervisory powers. A VASP license is therefore assessed against local law, not issued by FATF.
European Union The maximum MiCA grandfathering period ended on 1 July 2026. An old national registration no longer provides that transitional basis for continuing operations, as ESMA’s statement explains. See crypto licensing in Europe for regional route selection.
Local presence and territorial rules can change the setup required.
Market
Requirement or trigger
European Union
Article 63 applicants need a registered office in a member state where they provide some services, effective management in the EU and at least one EU-resident director under Article 59.
Financial-promotion rules can apply to marketing to UK consumers even where the company is overseas, as the FCA explains.
What Ongoing Compliance Duties Follow?
Plan AML/CFT controls as operating responsibilities, with named owners and evidence of completion. Depending on applicable law, these cover customer checks, transaction monitoring, suspicious-activity reporting, records and Travel Rule information, reflecting FATF’s preventive standards. Governance, capital and reporting duties must also be checked against the specific regime. VARA, for example, requires both compulsory and activity-specific rulebooks.
Loss of operating basis:ESMA’s post-transition instructions require unauthorised CASPs to stop new EU onboarding and wind down affected activities.
Frequently Asked Questions
Does a VASP license allow worldwide operations?
No. Check each customer market separately. A non-EU permission does not create MiCA passporting rights.
Can the company start trading once it is incorporated?
Do not treat incorporation as operational approval. Check the authority’s decision and any outstanding conditions before onboarding customers, as illustrated byVARA’s licensing stages.
Can compliance be fully outsourced?
Outsourcing does not necessarily transfer accountability. UnderMiCA Article 73, CASPs retain responsibility and must oversee outsourced functions.
Can services be added after approval?
Check before launch. For example,MiCA Article 59(8) requires an extension application for additional crypto-asset services.
Does a VASP license ensure a bank account?
No. Banks, EMIs and payment service providers make separate onboarding decisions. TheFCA’s financial-crime guidance, for example, calls for risk-based assessment of customers, ownership, funding and account activity.
Can a fixed preparation fee include a guaranteed decision date?
No. A professional fee covers agreed work. It cannot bind the regulator’s decision or remove requests for further evidence.
Gofaizen & Sherle has successfully implemented all the tasks related to the settlement of legal part (company formation and VASP license application) of our exchange whitebit.com.
Services Provided: End-to-end support with company share transfers in Lithuania and the USA (Montana), corporate account opening, AML/KYC policy development, regulatory compliance for FNTT and FinCEN, MICA licensing advisory, HR recruitment for C-level and AML roles, and payroll accounting services.
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