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Holy See

Retail_Trading_Status

Unclear Unknown
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Analysis ID
#122
Version
Archived
Created
2025-04-12 06:47
Workflow Stage
Live

Executive Summary

The regulatory status of retail cryptocurrency trading in the Holy See (Vatican City State) is Unclear, as there are no specific laws directly addressing it. The primary financial regulator, ASIF, focuses on traditional finance and AML/CFT supervision, but its mandate's extension to cryptocurrency is undefined. While no explicit ban exists, the Holy See expresses concerns about crypto's use in illicit activities and advocates for international regulation. The application of existing AML/CFT laws to individual crypto transactions is unclear, contributing to the ambiguity.

Key Pillars

The primary regulator is the Supervisory and Financial Information Authority (ASIF), but its role in regulating cryptocurrency is unclear. The core compliance requirements include AML/CFT obligations, but their specific application to individual cryptocurrency transactions is undefined. There are no apparent licensing or registration requirements for cryptocurrency exchanges or wallet providers operating within or targeting residents of the Holy See/Vatican City State.

Landmark Laws

Law No. XVIII of 8 October 2013 (subsequently amended): General AML/CFT provisions, application to cryptocurrency unclear.

Considerations

The legal classification of crypto assets in the Holy See is undefined, and there are no specific crypto tax laws. The Vatican has expressed serious concerns regarding the potential use of cryptocurrencies for illicit activities, particularly money laundering, human trafficking, and migrant smuggling. Practical access to cryptocurrency trading appears inconsistent, and at least one regulated international exchange explicitly lists the Holy See as a jurisdiction whose residents it cannot onboard due to regulatory factors.

Notes

Some sources suggest individuals can own and trade crypto assets despite the lack of specific regulation. The Holy See has expressed concerns regarding the potential use of cryptocurrencies for illicit activities and has called for greater international regulation. The UPay Blog stated in December 2024, "Vatican City doesn't truly have its specific cryptocurrency laws. Its Central Bank hasn't issued specific regulations or guidelines regarding cryptocurrency. This lack of direct regulation has created some ambiguity..." Some regulated international exchanges do not onboard residents of the Holy See due to regulatory factors.

Detailed Explanation

The legal status of retail cryptocurrency trading in the Holy See (Vatican City State) is Unclear. There are no specific laws explicitly permitting, prohibiting, or governing individual cryptocurrency activities. The primary financial regulator, the Supervisory and Financial Information Authority (ASIF), established in 2010 and updated in December 2020, focuses on financial intelligence, AML/CFT supervision, and prudential oversight of financial entities like the Vatican Bank (IOR). However, there is no clear indication that ASIF's mandate extends to regulating retail cryptocurrency trading or licensing Virtual Asset Service Providers (VASPs) operating within or targeting residents of the Holy See/Vatican City State.

While no outright ban is mentioned in official laws, and some sources suggest individuals can own and trade crypto assets, ambiguity remains. The Holy See has expressed concerns about cryptocurrency's potential use for illicit activities, particularly money laundering, human trafficking, and migrant smuggling, and has called for greater international regulation and transparency. The Holy See has robust AML/CFT laws, such as Law No. XVIII of 8 October 2013 (subsequently amended), and aims to comply with international standards set by MONEYVAL and FATF. However, it is unclear how these AML/CFT provisions apply to individual cryptocurrency transactions conducted through external platforms, or what KYC/AML obligations directly apply to residents beyond those imposed by external platforms themselves.

Practical access to cryptocurrency trading appears inconsistent. While some directories list exchanges potentially available to Vatican City residents, at least one regulated international exchange explicitly lists the Holy See (Vatican City) as a jurisdiction whose residents it cannot onboard due to regulatory factors. This conflict contributes to the uncertainty. Some sources note the potential indirect influence of Italian cryptocurrency regulations due to the unique geographical and political relationship, but this does not constitute a formal regulatory framework within the Holy See/Vatican City State itself. A lack of specific crypto tax laws within the jurisdiction is also noted. The UPay Blog in December 2024 stated, "Cryptocurrency is unregulated in Vatican City; however, people can own and trade crypto assets."

In summary, the absence of specific legislation, the regulator's focus on traditional finance (IOR), official expressions of concern regarding risks, unclear application of general AML/CFT rules, and conflicting information on practical access contribute to the status being classified as Unclear.

Summary Points

Okay, here's the regulatory analysis of Retail_Trading_Status in the Holy See, converted into a clear, well-structured bullet point format:

Retail Cryptocurrency Trading Status in Holy See (Vatican City State)
Report Date: April 12, 2025
Status: Unclear

I. Overall Regulatory Status:

  • Unclear: No specific legislation or regulation explicitly permits, prohibits, or governs retail cryptocurrency trading (buying, selling, holding by individuals).
  • Ambiguity: Lack of direct regulation creates uncertainty.
  • Practical Permissibility: Some sources suggest individuals can own and trade crypto assets, but this is not definitively confirmed.
  • Conflicting Information: Some exchanges are potentially available to Vatican City residents, while others explicitly exclude them due to regulatory factors.

II. Key Regulatory Bodies and Their Roles:

  • Supervisory and Financial Information Authority (ASIF):
    • Primary financial regulator.
    • Mandate focuses on:
      • Financial intelligence.
      • Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) supervision.
      • Prudential supervision of entities performing financial activities professionally.
    • Supervisory activities primarily directed towards the Institute for Works of Religion (IOR), commonly known as the Vatican Bank.
    • No indication that ASIF's mandate currently extends to regulating retail cryptocurrency trading or licensing Virtual Asset Service Providers (VASPs).

III. Important Legislation and Regulations:

  • Lack of Specific Crypto Legislation: No specific cryptocurrency laws or regulations issued by the Holy See.
  • AML/CFT Laws: Robust AML/CFT laws exist (e.g., Law No. XVIII of 8 October 2013, subsequently amended).
    • Holy See has been working to improve compliance with international standards set by MONEYVAL and FATF.
  • Unclear Application: It is unclear how general AML/CFT provisions specifically apply to individual cryptocurrency transactions.
  • No Specific Crypto Tax Laws: Lack of specific crypto tax laws within the jurisdiction.

IV. Requirements for Compliance:

  • Unclear KYC/AML Obligations: Unclear what KYC/AML obligations, if any, fall directly on residents engaging in cryptocurrency activities beyond those imposed by external platforms.

V. Notable Restrictions or Limitations:

  • Cautious Stance: The Holy See has expressed serious concerns regarding the potential use of cryptocurrencies for illicit activities, particularly money laundering and the financing of human trafficking and migrant smuggling.
  • Call for International Regulation: Official statements often call for greater international regulation and transparency in the crypto space, indicating a cautious and potentially wary stance.
  • Restricted Access: Some regulated international exchanges explicitly list the Holy See (Vatican City) as a jurisdiction whose residents they cannot onboard.

VI. Recent Developments or Changes:

  • ASIF Mandate Update: ASIF's mandate was updated most recently via statute in December 2020.
  • MONEYVAL Improvements: The Holy See has improved its measures for tackling money laundering and combating financing of terrorism, as concluded by MONEYVAL in a follow-up report released May 28, 2024.
  • Ongoing Concerns: Concerns regarding the potential risks and ethical implications of cryptocurrency remain.

VII. Potential Influences:

  • Indirect Influence of Italian Regulations: Potential indirect influence of Italian cryptocurrency regulations due to the unique geographical and political relationship, but this does not constitute a formal regulatory framework within the Holy See/Vatican City State itself.

Full Analysis Report

Report: Retail Cryptocurrency Trading Status in Holy See (Vatican City State)

Report Date: April 12, 2025
Jurisdiction: Holy See (Vatican City State)

Topic: Retail_Trading_Status

Description: Assessment of the legal permissibility for individual citizens and residents in the Holy See (Vatican City State) to buy, sell, and hold cryptocurrencies, including details on the regulatory environment, KYC/AML requirements, and official warnings.

1. Current Status: Unclear

2. Detailed Narrative Explanation:

The legal and regulatory status of retail cryptocurrency trading (buying, selling, holding by individuals) in the Holy See (which operates from the territory of the Vatican City State, often treated as a single entity for financial regulation purposes) is currently Unclear. There appears to be no specific legislation or regulation explicitly permitting, prohibiting, or governing cryptocurrency activities for individuals within the jurisdiction.

The primary financial regulator is the Supervisory and Financial Information Authority (Autorità di Supervisione e Informazione Finanziaria - ASIF). ASIF's mandate, established in 2010 and updated most recently via statute in December 2020, focuses on financial intelligence, Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) supervision, and prudential supervision of entities performing financial activities professionally [2, 6, 12, 18]. Its supervisory activities seem primarily directed towards the Institute for Works of Religion (IOR), commonly known as the Vatican Bank [6, 14]. There is no indication from available sources that ASIF's mandate currently extends to regulating retail cryptocurrency trading or licensing Virtual Asset Service Providers (VASPs) like exchanges or wallet providers operating within or targeting residents of the Holy See/Vatican City State.

While there is no outright ban mentioned in official laws or regulations, and some sources suggest individuals are practically able to own and trade crypto assets [5], significant ambiguity remains. The Holy See, through official representatives, has expressed serious concerns regarding the potential use of cryptocurrencies for illicit activities, particularly money laundering and the financing of human trafficking and migrant smuggling [5, 10]. These statements often call for greater international regulation and transparency in the crypto space, indicating a cautious and potentially wary stance, rather than explicit approval [10].

The Holy See has robust AML/CFT laws (e.g., Law No. XVIII of 8 October 2013, subsequently amended) and has been working to improve compliance with international standards set by bodies like MONEYVAL and the Financial Action Task Force (FATF) [2, 4, 8, 14]. However, it is unclear how these general AML/CFT provisions specifically apply to individual cryptocurrency transactions conducted through platforms potentially based outside the jurisdiction, or what KYC/AML obligations, if any, fall directly on residents engaging in such activities beyond those imposed by the external platforms themselves.

Furthermore, practical access appears inconsistent. While some directories list exchanges potentially available to Vatican City residents [7], at least one regulated international exchange explicitly lists the Holy See (Vatican City) as a jurisdiction whose residents it cannot onboard due to regulatory factors [19]. This conflict adds to the uncertainty.

Some sources note the potential indirect influence of Italian cryptocurrency regulations due to the unique geographical and political relationship [5], but this does not constitute a formal regulatory framework within the Holy See/Vatican City State itself. One source also mentions a lack of specific crypto tax laws within the jurisdiction [5].

In summary, the absence of specific legislation, the regulator's apparent focus on traditional finance (IOR), official expressions of concern regarding risks, unclear application of general AML/CFT rules to this specific activity, and conflicting information on practical access contribute to the status being classified as Unclear.

3. Relevant Text Excerpts:

  • On Lack of Specific Regulation and Permissibility:

    • "Cryptocurrency is unregulated in Vatican City; however, people can own and trade crypto assets." (UPay Blog, Dec 2024) [5]
    • "Vatican City doesn't truly have its specific cryptocurrency laws. Its Central Bank hasn't issued specific regulations or guidelines regarding cryptocurrency. This lack of direct regulation has created some ambiguity..." (UPay Blog, Dec 2024) [5]
    • "The legality of bitcoin and other cryptocurrencies in The Vatican City is currently unknown." (Bitrawr, 2025) [7]

  • On Vatican Concerns:

    • "The Vatican urged the international community to regulate cryptocurrency, especially because of its growing use in the smuggling and exploitation of migrants and vulnerable persons." (National Catholic Reporter, Oct 2021) [10]
    • "While some online platforms oblige their clients...to identify themselves, some cryptocurrency platforms and virtual asset service providers do not request identification from their customers...As is well known, this only increases opportunities for money laundering and similar crimes," (Statement by Msgr. Janusz Urbanczyk, Vatican representative, quoted in National Catholic Reporter, Oct 2021) [10]
    • "...the government's stance on cryptocurrency remains cautious due to concerns about potential risks and ethical implications." (UPay Blog, Dec 2024) [5]

  • On ASIF's Role:

    • "The Supervisory and Financial Information Authority (Autorità di Supervisione e Informazione Finanziaria, ASIF) is the competent authority of the Holy See and Vatican City State for financial intelligence, for AML/CFT supervision, for prudential supervision of entities that carry out a financial activity on a professional basis, for regulation for prudential purposes and, in the cases provided for by law, for AML/CFT regulation." (ASIF Official Website Information / Google Search Snippet) [2]
    • "Furthermore, ASIF is also the central authority for the supervision and prudential regulation of entities that professionally carry out financial activities (to date, exclusively the Istituto per le Opere di Religione)." (ASIF Wikipedia Page / Google Search Snippet) [6]

  • On Restricted Access (Example):

    • "At this time, we are not able to onboard clients that are residents of: [...] Holy See (Vatican City) [...]" (Zondacrypto Exchange Website, Non-acceptable countries list) [19]

  • On AML/CFT Framework:

    • "The Holy See (including Vatican City State) has improved its measures for tackling money laundering and combating financing of terrorism, concludes MONEYVAL in a follow-up report released today [May 28, 2024]." (Council of Europe / MONEYVAL News Release) [4]

4. Source Links:

  • [2] ASIF Mandate (via Google Search Snippet): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAId2meR-djqAH3-FiU7ZlwtPgDdn8V54Gl2-wTcXBPZoiZ8ctmCjcO4IaHK7L6-jDrrH7a_eHJ-PWloC30ldq2K4zhMW5lOq6ouoQ== (Note: Link points to search result context, primary source is ASIF website: https://asif.va/en/)
  • [4] MONEYVAL Report Update (Council of Europe): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIJMMnfwVi1EOaKxPlPjIIfQDojixBwcK22YK4xOcLX-Hc2urdQR4B-vYV0pvALr53dY6RabPMzVkUCigkqiKEabMcaKmebiBFmVmTejDqbg4ujqFxVfqHD7_S0YxWrPFyw1HJ7u64ysSZltgkQa-QLgcav95fg0-yApNSDSJeY8vVQN7Qbu56506Mp0zxUVVn4zLdVhlOqceeZSsOi9Lrm6PjTN8DI-IIGmMKKdBuqbLY0zot3pMQkKZ15muPwVwLpiTcM55S5r8c3n8s3cQAFF0-V6JvnZlXI-quKdn5i3j8F50VAPNgOrWqg-0fZ54QUzk1nntpXjpUJPI-kfLk1Yg== (Primary link likely within: https://www.coe.int/en/web/moneyval/)
  • [5] UPay Blog - Crypto Adoption Vatican City: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJVmhVxu2OKv9qq9PARKDOMyzLNBM2I5jPFYznSZlgwH229sB8MAbYkhPCkhrreq2egB2HBLOSrxZkNqjkZ8HVXBlX54u8n7Ys9jmLuKaMFkhNzPtYlPCVguCkdlNeSmAgzt1JCA2m4lzMm (Primary link: https://upay.co.uk/blog/crypto-adoption-around-the-world-vatican-city)
  • [6] ASIF Wikipedia Page (English): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJa3Q8i4seCvZYnd0BP5xHl-mlHqyXX2ERHh1kFJvMNi7Fj52ZeAin6EtxXABn3ueWnSGs7Hj7YmyHNuMug8ADuf339s3Jj9dyU-wd34_z1C9M0nBAQ5cRjE8n6b1JSiLEzIFeD_3gJ0-FqztzWTQG6jrIKjnM5TOqVdZewwUCTKzM7rQwUxMWlCEepdq2YqvwMuQ== (Primary link: https://en.wikipedia.org/wiki/Supervisory_and_Financial_Information_Authority_(Vatican_City))
  • [7] Bitrawr Exchange List for Vatican City: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJpv3wNn2DhV_y9aiPxxXTwPFRlmuVTkY7nU8ZKll-4szKkR1rmeg9_9VlRBIT2twVHZvESnzTX9Qet1VpU23PFxSNwz0C5Jp2vhUxuDZH1e2rVqK9hxPcFNA3sqq4Q (Primary link: https://bitrawr.com/buy-bitcoin/vatican-city)
  • [8] FATF Page on Holy See: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJixeYSTp-i1gc57AtRcNieSJ1KUOu8AO6pwZThTLHhX5ocVPYSr9Mc9vETJRgbYlTwJvixmh-syfl1Sibv3D1_bVbk6IuCSwiDj9O_2K6Sor6ORdK-aTRdRmtOL4a8bunbyZqDuD7SpPxovEJmXiDxnQ== (Primary link: https://www.fatf-gafi.org/en/countries/detail/Holy-See.html)
  • [10] National Catholic Reporter - Vatican Warning on Crypto: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIRngn7tZBbwJUsf39WZToZlAXNuJrn61o81sucvTZddWn7UZLnDxpwAThdhl4Q_6Asbg7_q6hJF2aEaR5f4NPsIj4px5QWWyxgPOufMisdMpsKP3UhA0jS99nOGf2Ki1BajmuLD9-ApUhZR-slc1dvSCSmKCcuyLkWHhQCKNDV3ZSgZPnVfoqRURnNI4t8-g== (Primary link: https://www.ncronline.org/news/vatican-warns-use-cryptocurrency-migrant-smuggling)
  • [12] ASIF Official Website (Italian) / Google Search Snippet: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIHnXAsLFWM8G935dQ07z_eX1vCnRmhSzMD1xvCEF3l2oBo9UmO0Qk9qYCtWqwghmWqYSRBV2X66Z5U3T6mJBK1hGcRcJNuKU3Aq5RRgbfm0_wVGsjVRvI= (Primary link: https://asif.va/it/)
  • [14] US State Dept INCSR Report (Older, but context on IOR/AML): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIpV30R9i2a4Yj4pPDwouDL9d6mhsN88yYYAstsQ0qMGGfGDkkjyZJM7D7cnP3aM889rn1a8glkREiOK5KyImYhVr11JgHveGqQ-SqNLQRJvA8l8KiQx6SetLHwhSqE5Tro7q1mI74VUIJ4kfHnOZS3y9J3uEhP9W0TTeDLotb6 (Primary link: https://2009-2017.state.gov/j/inl/rls/nrcrpt/2014/vol2/222709.htm)
  • [18] Vatican News - FIA becomes ASIF: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAKmqoD0jxOsy31kCGNhJrKgOH2hoRzLev-nRwliFRGFbL5LjQhIzk9TuabrPGRz0D1_zypdWTsNwK253wU1mVL2v_VV3mSXFBAO4_AHTIRVszhr3nEpqz-Pd9Qvn89Zng5iuqzKWMKxTVLSJC9BGsAgAY3D1hK4VJcUcoRwF2-kHvzUV63PXNVNXu-05IPWM40B4tlSM1AroBBtd8m95B5iiDj-Xvc= (Primary link: https://www.vaticannews.va/en/vatican-city/news/2020-12/vatican-fia-asif-new-statute-financial-information-authority.html)
  • [19] Zondacrypto - Non-acceptable countries: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALr5oB6p1aklN8CWFfPHXnaDtYc_dUfdfBPJ1B-bXtiHyGHeH5-Vd_x9e6pSRKBbOG8HED4A_QVUS7Vn4co-oii_m4eLHnQp0Hb203LGMQqkxVsW2zd7D1in3qpqJsCFU01UcSMiXSOjlfMqf6zuL0= (Primary link: https://zondacrypto.com/en/legal/non-acceptable-countries)

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