Seychelles: VASP licensing and transitional operating status
Regulatory position reviewed 26 October 2026
Licensing and eligible entities
The Seychelles Virtual Asset Service Providers Act 2024 entered into force on 1 September 2024. The Financial Services Authority (FSA) licenses covered exchange, wallet, broking and investment-advice businesses, with separate registration provisions for relevant offerings. A domestic company or eligible International Business Company may apply; an individual is not an eligible licence applicant. Incorporation alone creates no VASP permission. FSA licensing guidelines FSA legal framework
The transitional application deadline for qualifying businesses already operating at commencement was 31 December 2024. The FSA distinguishes a licensed entity from an existing provider permitted to continue while a complete timely application is assessed. A listing under an assessment heading should not be described as a full licence. A new entrant needs approval before beginning the service. FSA VASP FAQ FSA transition notice
What the operating model must support
The application guidelines and implementing regulations address the business plan, owners and management, financial resources, local arrangements and operational and compliance controls. AML/CFT and client-asset requirements remain relevant across the approved service. The institution should use the current activity-specific capital and continuing requirements; a general IBC formation cost or historic tax description does not establish them. FSA licensing guidelines FSA legal framework
For a custody or execution workflow, management needs evidence of customer balances, authority to move assets, reconciliation and response to a failed or suspicious transfer. When several group companies share a platform, the customer must still be able to identify the entity responsible for the regulated service. This is an institutional control implication of the licensing framework rather than a finding about any named operator. FSA licensing guidelines
Checking counterparties
Before engaging a provider, obtain its current FSA status, approved activities and conditions, and distinguish those from a pending application. Continuation can end with refusal, withdrawal or a supervisory decision. The Seychelles permission also does not establish foreign marketing rights or banking acceptance. The legal framework and individual decision should be checked with local counsel for the proposed transactions. FSA VASP FAQ FSA legal framework
Official primary sources
This research reflects official material reviewed as at 26 October 2026. It is informational and does not constitute legal advice, a licence determination or external legal review. The proposed activities and cross-border arrangements require assessment by qualified counsel.