Glossary
What is a virtual asset service provider (VASP)?
A virtual asset service provider (VASP) is a business that conducts virtual-asset activities for or on behalf of customers — exchanging crypto for fiat or other crypto, transferring it, safekeeping it, or providing financial services around its issuance — as defined by the Financial Action Task Force.
"VASP" is the load-bearing term of global crypto regulation. When the Financial Action Task Force extended its anti-money-laundering standards to crypto in 2019, it needed a definition of who those standards bind — and VASP is that definition. National regimes translate it into their own registration categories, but the FATF term is the common denominator regulators, banks and compliance teams use.
Whether a business is a VASP is therefore not a label choice but a legal trigger: falling inside the definition brings registration, AML program, screening and Travel Rule obligations.
Which activities make a business a VASP?
FATF defines a VASP as any natural or legal person conducting one or more of five activities as a business, for or on behalf of another person:
- Exchange between virtual assets and fiat currencies — the classic exchange or brokerage.
- Exchange between one or more forms of virtual assets — crypto-to-crypto trading and conversion services.
- Transfer of virtual assets — moving value on behalf of customers, including custodial payment and remittance services.
- Safekeeping or administration of virtual assets or instruments enabling control over them — custody and hosted wallets.
- Participation in and provision of financial services related to an issuer's offer or sale of a virtual asset — token issuance support.
What obligations does a VASP have?
The FATF standards, as implemented nationally, put VASPs under the same core regime as other financial institutions: registration or licensing with the national authority (money-services-business registration with FinCEN in the US, CASP authorization under MiCA in the EU, FCA registration in the UK, and equivalents elsewhere), a risk-based AML program with customer due diligence and suspicious-activity reporting, sanctions compliance, and the Travel Rule — transmitting originator and beneficiary information alongside transfers above the threshold.
Sanctions screening runs through several of those obligations at once: onboarding checks on customers, counterparty checks on transfers, and jurisdiction controls on where the service is offered.
Are DeFi protocols and wallet providers VASPs?
The boundaries are where the definition is contested. Purely self-hosted wallet software — where the user alone controls keys — generally falls outside the definition, because no one is acting on behalf of another. For DeFi, FATF guidance looks through the "decentralized" label to control and profit: where identifiable parties maintain control or sufficient influence over a protocol or its front-end as a business, those parties may qualify as VASPs even if the contracts are automated.
In practice many DeFi front-end operators adopt VASP-style controls — screening connecting wallets, geofencing restricted jurisdictions — both to manage sanctions exposure and to stay ahead of the regulatory direction of travel.
Where screening fits in a product
Customer onboarding checks
Screen the identifiers your registration obligations require you to collect — emails, government IDs, websites — against the enabled lists.
OFAC API — screen against the official SDN list →Transfer counterparty screening
Check the wallet addresses on both sides of a transfer before it settles, as part of transfer-rule and sanctions controls.
Wallet screening API for crypto compliance →Jurisdiction gating
Geolocate sessions and apply your policy for sanctioned and restricted jurisdictions, with VPN detection as a confidence signal.
IP Geofencing API for Sanctioned Countries →Scope
Whether your business qualifies as a VASP — and which national regime applies — is a legal determination for qualified counsel; this article summarizes the FATF framework for orientation. CompliAPI supplies screening infrastructure a VASP program uses: direct list checks, geolocation and VPN signals, and logged requests. It does not provide registration, KYC identity verification or Travel Rule messaging.
Frequently asked questions
Is VASP the same as MSB or CASP?
They overlap but belong to different regimes: VASP is the FATF standard's term, MSB (money services business) is the US registration category under FinCEN, and CASP (crypto-asset service provider) is the EU category under MiCA. A crypto exchange is typically all three at once.
Is a self-hosted wallet developer a VASP?
Generally no, under FATF guidance — publishing software that users run with their own keys is not conducting activities on behalf of another. The analysis changes if the developer operates custodial features or exchange-like services around it.
When is a DeFi project treated as a VASP?
When identifiable parties maintain control or sufficient influence over the service as a business — FATF guidance looks at facts, not the "decentralized" label. Front-end operators with admin keys, fee streams or upgrade control are the commonly cited cases. Where any given project falls is a legal question.
What screening obligations follow from VASP status?
Sanctions checks on customers and transaction counterparties, ongoing re-screening as lists change, and jurisdiction controls — alongside the KYC, monitoring and reporting duties of the AML program. The exact requirements depend on the national regime implementing the FATF standards.
Related solutions and data sources
Sanctions screening
OFAC API — screen against the official SDN list
Screen crypto wallets, emails, IDs and countries against the official US Treasury OFAC SDN list, refreshed every 15 minutes.
Sanctions screening
Wallet screening API for crypto compliance
Automated crypto wallet and address screening against OFAC and global sanctions lists in one GET request.
Access controls
IP Geofencing API for Sanctioned Countries
Geofencing API for compliance teams: geolocate any IP to country, region and city and get an OFAC sanctioned-country flag in the same response.
Data sources behind this term: US OFAC SDN, EU sanctions
Related terms: Anti-money laundering (AML), Sanctions screening, Sanctions
From the blog: OFAC compliance best practices for DeFi platforms →
Screening infrastructure for VASP obligations
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