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Retail cryptocurrency trading is legal and formally regulated in Vanuatu. The Vanuatu Financial Services Commission (VFSC) oversees the sector under the Virtual Asset Service Providers (VASP) Act, enacted in early 2025 (often cited as the VASP Act of 2024 in draft forms). This legislation establishes a comprehensive licensing regime for exchanges and custodians, building upon the earlier 'Class D' license framework introduced in 2021. While cryptocurrencies are not legal tender, individuals are free to buy, sell, and hold them, provided they use licensed intermediaries.
Retail cryptocurrency trading is legal and formally regulated in Vanuatu. The Vanuatu Financial Services Commission (VFSC) oversees the sector under the Virtual Asset Service Providers (VASP) Act, enacted in early 2025 (often cited as the VASP Act of 2024 in draft forms). This legislation establishes a comprehensive licensing regime for exchanges and custodians, building upon the earlier 'Class D' license framework introduced in 2021. While cryptocurrencies are not legal tender, individuals are free to buy, sell, and hold them, provided they use licensed intermediaries.
Key Pillars
Vanuatu Financial Services Commission (VFSC) as the primary regulator
Virtual Asset Service Provider (VASP) License requirements
Mandatory AML/CTF compliance under the Anti-Money Laundering and Counter-Terrorism Financing Act
Physical presence requirement for licensees (local office and management)
Fintech Sandbox Utility for testing innovative financial products
Vanuatu Financial Services Commission (VFSC) as the primary regulator
Virtual Asset Service Provider (VASP) License requirements
Mandatory AML/CTF compliance under the Anti-Money Laundering and Counter-Terrorism Financing Act
Physical presence requirement for licensees (local office and management)
Fintech Sandbox Utility for testing innovative financial products
Landmark Laws
Virtual Asset Service Providers Act (Act No. of 2024 / 2025) - Enacted: 2025-03-26
- A comprehensive framework regulating VASPs, requiring them to obtain licenses for exchange, custody, and ICO services. It grants the VFSC enforcement powers and mandates strict AML/KYC compliance.
- Source
Financial Dealers Licensing (Amendment) Act (Act No. 9 of 2021) - Enacted: 2021-07-01
- Amended the principal act to introduce a 'Class D' license specifically for dealing in digital assets, marking the first formal regulation of the sector.
- Source
Anti-Money Laundering and Counter-Terrorism Financing Act (Act No. 13 of 2014) - Enacted: 2014-01-01
- Establishes the general AML/CTF obligations that all financial dealers, including crypto service providers, must adhere to.
Virtual Asset Service Providers Act (Act No. of 2024 / 2025) - Enacted: 2025-03-26
- A comprehensive framework regulating VASPs, requiring them to obtain licenses for exchange, custody, and ICO services. It grants the VFSC enforcement powers and mandates strict AML/KYC compliance.
- Source
Financial Dealers Licensing (Amendment) Act (Act No. 9 of 2021) - Enacted: 2021-07-01
- Amended the principal act to introduce a 'Class D' license specifically for dealing in digital assets, marking the first formal regulation of the sector.
- Source
Anti-Money Laundering and Counter-Terrorism Financing Act (Act No. 13 of 2014) - Enacted: 2014-01-01
- Establishes the general AML/CTF obligations that all financial dealers, including crypto service providers, must adhere to.
Considerations
Cryptocurrencies are explicitly defined as 'not legal tender' by the VFSC.
Retail investors are warned that they are not protected by statutory compensation schemes if a platform fails.
Licensees must maintain a physical office and key personnel (Manager, Director, CTO) within Vanuatu.
The VASP Act excludes Central Bank Digital Currencies (CBDCs) and digital representations of fiat from its definition of virtual assets.
Strict penalties exist for operating without a license, including fines up to 250 million Vatu and imprisonment.
Cryptocurrencies are explicitly defined as 'not legal tender' by the VFSC.
Retail investors are warned that they are not protected by statutory compensation schemes if a platform fails.
Licensees must maintain a physical office and key personnel (Manager, Director, CTO) within Vanuatu.
The VASP Act excludes Central Bank Digital Currencies (CBDCs) and digital representations of fiat from its definition of virtual assets.
Strict penalties exist for operating without a license, including fines up to 250 million Vatu and imprisonment.
Notes
The analysis reflects the regulatory landscape as of late 2025. The passage of the VASP Act in March 2025 marks a significant maturation from the 2021 'Class D' amendment, moving Vanuatu from a general financial dealer model to a specific VASP regulatory model comparable to other sophisticated jurisdictions.
The analysis reflects the regulatory landscape as of late 2025. The passage of the VASP Act in March 2025 marks a significant maturation from the 2021 'Class D' amendment, moving Vanuatu from a general financial dealer model to a specific VASP regulatory model comparable to other sophisticated jurisdictions.
Remaining Uncertainties
- The exact transition timeline for existing 'Class D' license holders to the new VASP Act regime is not fully detailed in public summaries.
- Specific capital requirement amounts under the new VASP Act (as opposed to the old Class D bond of 5 million Vatu) need verification from the full text of the 2024/2025 Act.
- The exact transition timeline for existing 'Class D' license holders to the new VASP Act regime is not fully detailed in public summaries.
- Specific capital requirement amounts under the new VASP Act (as opposed to the old Class D bond of 5 million Vatu) need verification from the full text of the 2024/2025 Act.
Source Evidence
Source Evidence
"These Guidelines are issued under Section 59 of the Virtual Asset Service Providers Act... to ensure that applicants seeking to be licensed as VASPs..."
"The Financial Dealers Licensing (Amendment) Act No. 9 of 2021 created four (4) classes of FDL licenses... Class D license authorizes the regulated..."
"Virtual Assets or Cryptocurrencies, unlike fiat currencies, are not legal tender in Vanuatu... the VFSC does not recommend them for retail investors..."
"The South Pacific Island nation's Parliament passed the 'Virtual Asset Service Provider (VASP) Act' on March 26."
"On March 26, the local parliament passed the Virtual Asset Service Providers Act, granting the Vanuatu Financial Services Commission (VFSC) the..."
"These Guidelines are issued under Section 59 of the Virtual Asset Service Providers Act... to ensure that applicants seeking to be licensed as VASPs..."
"The Financial Dealers Licensing (Amendment) Act No. 9 of 2021 created four (4) classes of FDL licenses... Class D license authorizes the regulated..."
"Virtual Assets or Cryptocurrencies, unlike fiat currencies, are not legal tender in Vanuatu... the VFSC does not recommend them for retail investors..."
"The South Pacific Island nation's Parliament passed the 'Virtual Asset Service Provider (VASP) Act' on March 26."
"On March 26, the local parliament passed the Virtual Asset Service Providers Act, granting the Vanuatu Financial Services Commission (VFSC) the..."
Web Sources
Web Sources
9 sources
https://coingeek.com/vanuatu-passes-digital-asset-framework/
https://www.binance.com/en/square/post/04-01-2025-vanuatu-implements-strict-regulations-for-digital-assets-22319119265962
https://crypto.news/vanuatu-passes-crypto-licensing-and-regulation-framework/
https://fca.vu/vfsc-release-clarifying-the-new-rules-on-digital-assets-and-cryptocurrencies/
https://fca.vu/vanuatu-passes-virtual-asset-service-providers-vasp-act/
https://vanuatucbipassport.com/is-crypto-legal-in-vanuatu/
https://vimb.vu/vanuatus-bold-leap-into-the-future/
https://www.vfsc.vu/wp-content/uploads/2025/06/Guidence-Digital-Asset.pdf
https://atomiqconsulting.com/crypto-license/vanuatu/
9 sources
https://coingeek.com/vanuatu-passes-digital-asset-framework/
https://www.binance.com/en/square/post/04-01-2025-vanuatu-implements-strict-regulations-for-digital-assets-22319119265962
https://crypto.news/vanuatu-passes-crypto-licensing-and-regulation-framework/
https://fca.vu/vfsc-release-clarifying-the-new-rules-on-digital-assets-and-cryptocurrencies/
https://fca.vu/vanuatu-passes-virtual-asset-service-providers-vasp-act/
https://vanuatucbipassport.com/is-crypto-legal-in-vanuatu/
https://vimb.vu/vanuatus-bold-leap-into-the-future/
https://www.vfsc.vu/wp-content/uploads/2025/06/Guidence-Digital-Asset.pdf
https://atomiqconsulting.com/crypto-license/vanuatu/
Full Analysis Report
Full Analysis Report
Vanuatu has established itself as a regulated offshore jurisdiction for cryptocurrency activities, transitioning from a general financial dealer framework to a dedicated legislative regime. The regulatory environment is anchored by the Virtual Asset Service Providers (VASP) Act, passed by Parliament in March 2025 (often referred to as the Act of 2024 during its bill stage). This Act empowers the Vanuatu Financial Services Commission (VFSC) to license and supervise all virtual asset service providers, including exchanges, wallet providers, and initial token offering (ITO) issuers. The legislation was designed to align Vanuatu with FATF Recommendation 16 (the Travel Rule) and other international AML/CFT standards.
Prior to the VASP Act, Vanuatu regulated crypto under the Financial Dealers Licensing (Amendment) Act No. 9 of 2021. This amendment introduced a 'Class D' license, which specifically authorized the distribution, secondary trading, and custody of digital assets. For several years, this was the primary route for crypto brokers to operate legally from Vanuatu. The new VASP Act expands on this by creating a more granular licensing system and explicitly defining 'virtual assets' while excluding digital representations of fiat currency and securities, which remain under traditional financial laws.
Retail trading is fully permitted; there are no laws prohibiting individuals from owning or trading digital assets. However, the VFSC has issued multiple warnings clarifying that cryptocurrencies are not legal tender and that retail investors engage in the market at their own risk, without the safety net of statutory compensation funds. The regulator emphasizes consumer protection through the licensing of providers rather than through direct restrictions on users.
Operational requirements for licensees are stringent to prevent 'shell' operations. Entities must maintain a physical presence in Vanuatu, including a local office and resident management (Director, Manager, and CTO). They are also subject to rigorous AML/KYC obligations, including the requirement to maintain details of Ultimate Beneficial Owners (UBOs) and conduct customer due diligence. The VFSC has also introduced a Fintech Sandbox Utility, allowing companies to test new products in a controlled environment for up to 12 months.
Vanuatu has established itself as a regulated offshore jurisdiction for cryptocurrency activities, transitioning from a general financial dealer framework to a dedicated legislative regime. The regulatory environment is anchored by the Virtual Asset Service Providers (VASP) Act, passed by Parliament in March 2025 (often referred to as the Act of 2024 during its bill stage). This Act empowers the Vanuatu Financial Services Commission (VFSC) to license and supervise all virtual asset service providers, including exchanges, wallet providers, and initial token offering (ITO) issuers. The legislation was designed to align Vanuatu with FATF Recommendation 16 (the Travel Rule) and other international AML/CFT standards.
Prior to the VASP Act, Vanuatu regulated crypto under the Financial Dealers Licensing (Amendment) Act No. 9 of 2021. This amendment introduced a 'Class D' license, which specifically authorized the distribution, secondary trading, and custody of digital assets. For several years, this was the primary route for crypto brokers to operate legally from Vanuatu. The new VASP Act expands on this by creating a more granular licensing system and explicitly defining 'virtual assets' while excluding digital representations of fiat currency and securities, which remain under traditional financial laws.
Retail trading is fully permitted; there are no laws prohibiting individuals from owning or trading digital assets. However, the VFSC has issued multiple warnings clarifying that cryptocurrencies are not legal tender and that retail investors engage in the market at their own risk, without the safety net of statutory compensation funds. The regulator emphasizes consumer protection through the licensing of providers rather than through direct restrictions on users.
Operational requirements for licensees are stringent to prevent 'shell' operations. Entities must maintain a physical presence in Vanuatu, including a local office and resident management (Director, Manager, and CTO). They are also subject to rigorous AML/KYC obligations, including the requirement to maintain details of Ultimate Beneficial Owners (UBOs) and conduct customer due diligence. The VFSC has also introduced a Fintech Sandbox Utility, allowing companies to test new products in a controlled environment for up to 12 months.