The Financial Services Authority of Saint Vincent & the Grenadines (SVG FSA) has issued revised requirements for Virtual Asset Business (VAB) applications under the Virtual Asset Business Act, 2022. Applicants are now required to provide a comprehensive submission addressing ten defined areas:
- Business Model & Activities — full description of all virtual asset activities (exchange, transfer, custody, brokerage, platform/technology provision)
- Legal Entity & Group Structure — corporate structure, parent/affiliated entities, operating jurisdictions, and existing licences
- Ownership, Governance & Control — identification of directors, senior management, UBOs, and governance arrangements
- Technology & Platform Infrastructure — platform/software details, third-party providers, cybersecurity controls, and incident response
- Custody & Asset Control — whether client assets are held, key management arrangements, and asset safeguarding measures
- AML/CFT Framework — CDD/KYC, transaction monitoring, suspicious activity reporting, FATF Travel Rule implementation, blockchain analytics tools
- Customer Base & Jurisdictions Served — client types, jurisdictions covered, and high-risk jurisdiction restrictions
- Outsourcing & Third-Party Arrangements — all third-party reliance, agreements, and retained oversight mechanisms
- Financial Resources & Operational Capacity — capital evidence, financial projections, and risk management framework
- Physical Presence in SVG — local office, personnel, local directors, compliance officer, and operational staff
New Physical Presence Requirement
Of particular note, the FSA is now explicitly requiring applicants to establish on-shore physical substance within Saint Vincent & the Grenadines — a requirement that was not part of the original application framework. This represents a meaningful shift in what is expected of VASP applicants in this jurisdiction.
The physical presence requirement encompasses:
- A local office in Saint Vincent & the Grenadines
- Local personnel including operational staff
- Local directors resident in SVG
- A compliance officer with appropriate local presence
Second Revision — No Licenses Issued to Date
It is also worth observing that this is the second instance in which the SVG FSA has revised its requirements and introduced new stages for applicants already in the process, while no virtual asset business licences have been issued to date.
This pattern of evolving requirements mid-process, combined with the absence of any issued licenses under the VAB Act 2022, should be factored into the decision-making of firms considering SVG as a VASP licensing jurisdiction. Applicants should be prepared for potential further revisions and should assess whether the jurisdiction's regulatory framework has stabilized sufficiently to support their business planning timeline.
Alternative VASP Licensing Jurisdictions
For firms seeking VASP authorization with more established frameworks, Zitadelle AG advises on licensing in jurisdictions with active license issuance including:
- Cyprus MiCA CASP — EU-passportable crypto-asset service provider authorization
- Mauritius VASP License — established FSC framework with licenses actively issued
- El Salvador DASP — CNAD-licensed operators including Binance and Tether
- Labuan VASP — LFSA digital asset framework with clear substance requirements
Zitadelle AG Advisory
Zitadelle is actively monitoring regulatory developments across all VASP jurisdictions. For guidance on SVG applications or alternative licensing pathways, please contact us.
Last updated: May 2026. This article is for informational purposes only and does not constitute legal or regulatory advice. Contact Zitadelle AG or qualified legal counsel for advice specific to your circumstances.