Obtain Your Vanuatu VASP License with Zitadelle AG – Your Trusted Regulatory Partner

Zitadelle AG is your premier consultancy partner for navigating the complex regulatory landscape of Virtual Asset Service Provider (VASP) licensing in Vanuatu. With the Virtual Asset Service Providers Act No. 3 of 2025 now fully in force, Zitadelle AG is ready to support international clients seeking to establish a licensed VASP business under this modern and robust framework.

What Is the Virtual Asset Service Providers Act No. 3 of 2025?

The Vanuatu Financial Services Commission (VFSC) has officially gazetted the VASP Act, making it a binding regulatory framework for entities operating in the virtual asset and token economy. The Act governs:

• Virtual Asset Service Providers (VASPs)

• Initial Token Offerings (ITOs)

• Fintech Sandbox businesses

It introduces five classes of VASP licenses, provides clear AML/CFT guidelines, and sets the groundwork for a secure, transparent digital asset ecosystem in Vanuatu.

Why Choose Zitadelle AG for Your VASP License Application?

Zitadelle AG offers end-to-end support for your Vanuatu VASP license application, including:

✅ Regulatory guidance under the 2025 VASP Act
✅ Preparation and submission of application forms and documentation
✅ Fit and proper assessments for Directors, Managers, and CTOs
✅ Drafting internal policies (AML/KYC, governance, operational risk)
✅ Liaising with VFSC and your local registered agent
✅ Assistance in establishing local physical presence and staffing

Key VASP License Requirements in Vanuatu

To successfully apply for a VASP license in Vanuatu, the applicant must:

• Submit the prescribed application form and pay the relevant fees

• Clearly indicate the license class(es) applied for

• Have a physical office in Vanuatu and appoint key personnel (including a resident CTO and director)

• Maintain a minimum unimpaired capital of VT 200,000,000 (depends on the license class, but generally seen as 500,000.00 USD seen as a minimum or VUV 200 million being 1,6mln USD - > certified by an external auditor)

• Provide a business plan and service proposal

• Undergo a fit and proper test for all officers, directors, and managers

• Demonstrate AML/CFT compliance through an in-depth risk assessment

• Submit detailed KYC/CDD procedures and a source of funds declaration

AML, KYC & Operational Risk Requirements

All VASP applicants must meet rigorous Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) obligations, including:

• Risk-based assessment of ML/TF vulnerabilities

• Internal AML/CFT systems and controls

• Source of wealth/funds verification

• Ongoing suspicious activity monitoring

• External audits and risk control testing

Operational Risk Management (ORM) is also mandatory, requiring:

• Documented ORM policies and audit trails

• Regular penetration and vulnerability testing

• Transaction audit logs, proof-of-reserve procedures

• Blockchain-based immutable records (recommended)

Director, Manager & CTO Residency Requirements

Application & Licensing Fees (VT)

Fintech Sandbox Utility

Businesses developing innovative virtual asset solutions may apply for Vanuatu’s Fintech Sandbox, including:

• Virtual Asset Brokerage

• Wallet Services

• Custody Solutions

• Digital Asset Advisory

• Virtual Asset Exchanges

Applicants must show 1 year of experience in relevant fintech services. Licenses are granted for 12 months, with renewal options.

Custodian License (D.2): Special Requirements

A Class D.2 license allows safekeeping and control of virtual assets. Applicants must demonstrate:

• Governance protocols for fraud prevention and operational risk

• Secure seed/key generation and recovery processes

• Robust transaction authorization systems with KYC/CDD

• Ongoing custody system audits and penetration testing

• Full client disclosures and legal agreements

• Record retention for 7 years in accordance with VFSC guidelines

How Zitadelle AG Supports Your Vanuatu VASP Licensing Journey

At Zitadelle AG, we streamline the licensing process through:

• Regulatory consultation tailored to your business model

• Preparation of all required documentation

• Corporate structuring and governance setup

• Physical office arrangements in Vanuatu

• Recruitment of qualified directors, managers, and CTOs

• Post-licensing compliance and AML system implementation

Start Your Application Today

With the Vanuatu VASP regime now in full effect, early movers can benefit from this forward-thinking jurisdiction. Whether you're launching a crypto exchange, wallet service, token platform, or custody provider, Zitadelle AG offers the expertise and local partnerships needed for success.

📩 Contact us today to schedule a consultation and begin your VASP license application under the VFSC.