Crypto license in Seychelles

Pros and Cons of the Seychelles Crypto License

Like any jurisdiction, Seychelles’ crypto license comes with notable advantages and some drawbacks. Below is a summary of the pros and cons:

Pros:

• Favorable Tax Regime: Seychelles IBCs enjoy 0% tax on foreign-sourced profits, no capital gains tax, and no withholding taxes. This tax neutrality can significantly reduce operational costs for global crypto businesses.
• Business Privacy: While licensees must disclose directors and owners to the regulator, this information is not public, preserving confidentiality for beneficial owners.
• Lower Capital Barriers: The required paid-up share capital (EUR 22k–85k) is relatively moderate compared to some jurisdictions (e.g. EU licenses often require €150k+). Additionally, no upfront share capital deposit was historically required for Seychelles companies. The new rules do mandate capital, but the amounts remain accessible for startups.
• Supportive Regulatory Climate: Local authorities are cooperative and focused on growing the fintech sector. The FSA provides guidance (e.g. detailed application guidelines) and there’s a regulatory sandbox for fintech innovation. This pro-business approach helps streamline the licensing process.
• Fast Incorporation: Setting up a Seychelles IBC is quick (often within 1-2 weeks) and inexpensive (~ EUR 1,300), enabling rapid corporate establishment. The overall license timeline (~9 months) is reasonable for a new regime and may improve as the FSA processes more applications.
• Flexibility and Global Reach: A Seychelles license allows offering services internationally (subject to other countries’ laws) and covers a wide scope – exchanges, wallets, brokerage, ICOs, etc. – under one license. This one-stop scope provides operational flexibility for multi-service crypto firms.

Cons:

• Local Substance Requirements: The license demands real presence in Seychelles – including a local office, resident director, and staff. This adds ongoing costs (office rent, local hires) and may be challenging for companies without existing ties to Seychelles.
• Stringent Compliance Obligations: Seychelles now imposes strict AML/CFT compliance, requiring comprehensive internal policies (KYC, transaction monitoring, risk assessments) and regular reporting to authorities. Meeting these standards can be resource-intensive, especially for smaller startups.
• New Regulatory Framework: The VASP regime is brand new (effective late 2024), so there is limited track record. Companies face some uncertainty as the FSA works through first-time applications; the process and interpretations are still being refined. Early applicants may experience longer processing or additional queries as the regulator gains experience.
• Activity Restrictions: Certain crypto activities are off-limits in Seychelles. Notably, running mining farms or offering mixing/tumbling services are expressly prohibited. Businesses centered on these activities cannot be licensed here, which is a limitation compared to a few other jurisdictions.
• Higher Ongoing Fees: The annual fees for a Seychelles crypto license can be significant if multiple activities are covered (e.g. an exchange + wallet provider would pay €5k base + €25k + €20k = €50k per year to the regulator). While competitive for a regulated jurisdiction, these fees are higher than completely unregulated options and must be budgeted for annually.
• Banking Challenges: Although a Seychelles license improves credibility, securing international banking for crypto businesses can still be difficult. Seychelles is a smaller financial center, and companies might need to rely on offshore banking or payment processors for fiat operations. This is a general challenge for crypto firms, not unique to Seychelles, but worth noting as a practical consideration.

Types of Crypto Licenses in Seychelles

Under the VASP Act 2024, Seychelles offers four categories of crypto license, each corresponding to a different scope of services. A single company can apply for multiple categories if it intends to offer a range of services (and must pay the respective fee for each). The license categories are:

• Type A – Virtual Asset Wallet Provider: This license covers custodial or non-custodial wallet services and safekeeping of virtual assets for clients. It allows a company to provide secure storage of cryptocurrency, manage wallets on behalf of users, and facilitate transfers in/out of wallets. (It can also cover handling ICO/NFT tokens related to wallet services.)
• Type B – Virtual Asset Exchange: This is the classic cryptocurrency exchange license. It authorizes operating a platform to exchange virtual assets for fiat or other crypto. Services can include on-ramp/off-ramp conversion between fiat and crypto, crypto-to-crypto trading, and related custody/transfer functions that support the exchange operations. In short, any order-book exchange or brokerage that trades crypto assets falls under Type B.
• Type C – Virtual Asset Broking: This license is for intermediaries that facilitate trades without being a full exchange. A Type C licensee might operate as an OTC broker or a peer-to-peer trading facilitator, matching buyers and sellers of crypto or assisting clients in executing trades on external exchanges. It also covers brokerage related to ICOs/NFTs – for example, acting as an agent that helps clients buy into token offerings.
• Type D – Virtual Asset Investment Provider: This category covers crypto investment services. It allows the company to manage portfolios of virtual assets or offer investment advice involving crypto. For instance, a crypto asset manager, crypto hedge fund, or an advisory firm for crypto investments would need a Type D license. It includes providing investment advice on ICOs and NFTs as well.

These four license types ensure that Seychelles can regulate the full spectrum of crypto business models. Notably, Initial Coin Offering (ICO) and NFT issuance are handled via a registration for the token issuer (promoter) rather than a separate license type. A company launching an ICO or NFT collection must register with FSA but would also need one of the above licenses if it is providing services like exchange, custody, or brokerage related to those tokens. Each licensed VASP in Seychelles can engage only in the activities permitted by its category of license (or multiple categories if obtained). For example, a company licensed as an Exchange (Type B) and Investment Provider (Type D) could run a trading platform and offer portfolio management, but it could not engage in mining or unlicensed activities outside its scope.

Licensing Requirements in Seychelles

Obtaining a Seychelles crypto license involves meeting a comprehensive set of requirements. The FSA will scrutinize the applicant’s corporate setup, capital, management, policies, and controls to ensure the business is sound and compliant. Key licensing requirements include:

• Eligible Corporate Structure: The applicant must be a Seychelles-incorporated entity. Typically an International Business Company (IBC) is used, though domestic companies or special license companies can also apply. The company’s Memorandum & Articles should allow for crypto activities. All shares and beneficial owners must be disclosed to the regulator (but not publicly).
• Share Capital: The company must meet minimum paid-up capital thresholds as set by law. New entrants (not already operating pre-Act) need at least USD 75,000 (EUR 66,000) for a wallet provider, USD 100,000 (EUR 88,000) for an exchange, USD 50,000 (EUR 44,000) for a broker, or USD 25,000 (EUR 22,000) for an investment advisor. This capital must be fully paid-up before license issuance. Furthermore, by the third year of operation, licensees must maintain net assets equal to at least 2.5% of their annual turnover – ensuring capital adequacy grows with business volume. (Existing crypto businesses that were operating before the law have a similar 2.5% of turnover requirement from the start).
• Local Presence (Substance): Seychelles requires real local operations. The company must maintain a physical office in Seychelles that is fully staffed during business hours. A mere registered agent’s address is not sufficient – the FSA expects an operating office where management decisions and compliance are carried out. Additionally, the company must hold board meetings in Seychelles periodically. This substance requirement is intended to prevent “license only” shell companies and ensure meaningful oversight.
• Directors and Management: A minimum of two directors is required, and at least one director must be a Seychelles resident. Directors (and any key officers) must pass the FSA’s “fit and proper” test. This involves demonstrating relevant experience, qualifications, good reputation, financial integrity, and a clean criminal record. Background checks will be done – applicants must submit detailed CVs for directors, police clearance certificates, and financial reference letters. The board as a whole should have the competence to manage a crypto business. The FSA may also interview principals or request additional info to assess their suitability.
• Qualified Staff & Key Personnel: Beyond directors, qualified or experienced personnel must be employed to run the day-to-day operations. Crucially, the company needs to appoint a local Compliance Officer and a Money Laundering Reporting Officer (MLRO) in Seychelles. These roles can be held by the same person (if approved) or separate individuals. Their responsibility is to implement and oversee AML/CFT measures. The MLRO must reside in Seychelles to interface with authorities. Additionally, an approved auditor (licensed in Seychelles) must be engaged to audit the company annually.
• Internal Policies and Procedures: The application must include a comprehensive set of internal documentation demonstrating how the business will operate safely and compliantly. This typically includes: a detailed Business Plan (with financial projections), an Internal Procedures Manual for operations, a Compliance Manual, KYC/Customer Due Diligence procedures, Risk Assessment documentation, Cybersecurity Policy, Anti-Money Laundering/Countering Financing of Terrorism (AML/CFT) Manual, Client Asset Segregation Policy, Complaint Handling Policy, and more. Seychelles’ FSA expects these policies to align with FATF standards and local AML law. All these documents – often numbering a dozen or more – must be prepared prior to application. They will be reviewed by the regulator to ensure the company has robust systems in place for managing risks.
• AML/CFT Compliance Measures: Given the emphasis on AML, applicants must demonstrate strong controls against money laundering and terrorist financing. An Institutional Risk Assessment (IRA) is required as part of the application, documenting the firm’s assessment of its own risks and how it will mitigate them. The FSA’s guidelines require the IRA to consider national risk factors, the nature of services, transaction patterns, etc., and to be updated regularly. Additionally, the company should have tools for ongoing transaction monitoring, sanctions screening, and customer due diligence. During the application, the FSA may even request a live demonstration of the AML/CFT systems and software the company will use (e.g. blockchain analytics or KYC verification tools). This level of scrutiny underscores the importance of a solid compliance framework.
• Insurance and Safeguards: Licensees are required to maintain appropriate insurance coverage for the risks of their operations. Typically this means obtaining Professional Indemnity Insurance or a fidelity bond to cover losses from negligence, fraud, cyber incidents, etc. The insurance policy must be “commensurate with the nature and scale” of the business. For example, an exchange handling large volumes should have a higher coverage limit. Furthermore, client assets must be safeguarded – for instance, keeping customer funds in segregated accounts (which should be addressed in the company’s internal policies and evidenced to FSA).
• Fit-and-Proper & Source of Funds: All significant shareholders (owners) need to prove the legitimacy of their funding. The FSA will require evidence of source of funds/wealth for investors providing capital to the company. This might include bank reference letters, audited financial statements, proof of income, etc. The goal is to ensure criminal proceeds are not invested into the business. Similarly, any person with 10% or more shares is typically subject to the fit-and-proper checks. If any owner or director has a history of fraud, bankruptcy, or regulatory offenses, the application can be denied. Seychelles places great importance on the integrity and competence of those behind the company.

Cost Breakdown for a Seychelles Crypto License

One of the appealing aspects of Seychelles is its competitive cost structure for crypto licensing, especially compared to jurisdictions like Europe. There are several cost components to consider: government fees, professional service fees, and ongoing operational costs. Below is a breakdown:

• Government and License Fees: The application fee payable to the FSA is EUR 5,000 (one-time, non-refundable). Upon approval, the first year’s base license fee of EUR 5,000 must be paid, plus the fee for each specific activity the license covers. Annual fees per activity are: EUR 25,000 for an Exchange, EUR 20,000 for a Wallet provider, EUR 10,000 for Broking, and EUR 5,000 for Investment provider. These are annual fees to maintain the license. For example, a company licensed as both an exchange and wallet provider would pay €5k (base) + €25k + €20k = €50k each year. Fees are pro-rated in the first year depending on the quarter of license grant. All fees are payable to the FSA’s account (often in USD or EUR equivalent) at application and then every year before renewal.
• Company Formation Costs: Setting up a Seychelles IBC is relatively inexpensive. A typical incorporation package (through a registered agent) costs around €1,300 and includes government registration fees, a year of registered agent/office service, and document apostilles. If using a corporate service provider, they will handle the IBC registration. (This step is required before applying for the license, since you need a Seychelles company.)
• Local Office and Staffing: The cost of leasing a physical office in Seychelles can vary by location and size. Many firms opt for a modest office space in Mahé (the main island) or engage a management company that provides serviced office facilities. Office rent might range from a few hundred to a couple thousand euros per month depending on needs (this is usually an external expense; SBSB’s quotation lists office leasing as “on request” cost). Additionally, having at least one local director and possibly local staff (for compliance roles) entails salary or retainer costs. Local directors often receive a monthly fee for their directorship. These substance costs are important to budget for, as they are ongoing.
• Professional Advisory Fees: Given the complexity of the application, most companies hire legal consultants to prepare the license application, draft all required policies, and liaise with the FSA. Firms like SBSB or others offer “turnkey” licensing services. For instance, SBSB’s full service package for a Seychelles crypto license project is quoted around €20,520 (which includes company formation, document prep, application submission, and a bank account opening). Within that, the specific license application preparation fee is €15,425. While DIY is possible, using experienced lawyers can greatly improve the quality of the application and response to regulator queries. These professional fees are typically one-time (for initial license obtainment), though firms may charge separately for additional services like drafting extra policies or obtaining other registrations.
• Banking and Accounts: Crypto companies will need a corporate bank account (or payment institution account) for operational funds. Opening a local bank account in Seychelles might be challenging (many crypto firms use offshore banks or EMI accounts). SBSB’s estimate for opening a corporate account is about €3,300, which may include introductions to banking partners. Accounting and audit are another cost area: an annual financial audit by an approved auditor could cost a few thousand euros (depending on the auditor and volume of transactions). Basic bookkeeping services in Seychelles were quoted at around €215 for annual financial statements preparation and €210 for six months of accounting records (likely minimal transactions scenario). In practice, expect higher accounting costs if the business has substantial activity, but overall accounting fees in Seychelles are moderate.
• Ongoing Compliance Costs: Maintaining compliance has both internal and external costs. Internally, the company needs to invest in AML monitoring tools, KYC systems, and employee training. Externally, there may be costs for ongoing regulatory filings or engaging consultants to update policies. Seychelles may require periodic compliance audits or reviews – for example, some jurisdictions mandate an independent AML audit periodically. While not explicitly stated for Seychelles in 2024, it’s wise to budget for compliance advisory support annually. Also, if the business expands, additional license categories can be added for the respective fees (or if it chooses to cease an activity, it could drop that fee).
• Optional and Ancillary Services: Depending on the business plan, there could be other costs. For instance, if the company plans to offer fiat on-ramp, it might need a payment processing/merchant account integration – SBSB lists setting up a merchant account for ~€1,530. Similarly, if using nominee services for shareholders or directors (to enhance privacy), those come at an extra fee (often a few thousands annually, negotiated case by case). These optional services can be tailored to the client’s needs. The key is that Seychelles’ framework allows a lot of flexibility in structuring the business (you can have 100% foreign ownership, use nominees, etc., as long as transparency to the regulator is maintained).

In aggregate, a new entrant should expect initial setup costs (including fees and service providers) in the lower tens of thousands of euros – for example, roughly €25k–€30k covering incorporation, advisors, and first-year fees (not counting share capital injection). This is significantly more affordable than major financial hubs, making Seychelles a cost-effective licensing option. However, the recurring annual costs (license fees, office, local staff, audit) mean the business should have a sustainable revenue model to support ~€30k–€50k per year in fixed regulatory costs. Careful financial planning is essential.

Step-by-Step Process to Obtain the License

Obtaining a Seychelles crypto license is a multi-stage process that can take around 9 months in total. Here is a step-by-step overview of how an application typically proceeds:

1. Initial Consultation & Planning: It’s advisable to start by consulting with a Seychelles legal expert or corporate service provider. They will confirm eligibility and outline requirements. The company’s principals should prepare documents like passports, CVs, financial statements, etc., for due diligence at this stage. A name for the new company is chosen and checked for availability.
2. Company Incorporation: The first formal step is to register a Seychelles company (IBC or domestic company). This involves preparing incorporation documents (Memorandum & Articles of Association), and submitting to the Registrar via a local licensed agent. Incorporation is quick, often a few days once due diligence is passed. After incorporation, you receive the Certificate of Incorporation and other corporate docs.
3. Preparation of License Application Package: This is the most labor-intensive stage. The team will prepare all required licensing documents and forms for the FSA. This includes drafting the full suite of internal policies (AML manual, compliance program, security policies, etc.), the business plan and financial forecasts, completing the official application form, and gathering supporting documents (director IDs, resumes, police records, bank reference letters, proof of funds, etc.). All documents should be in English and, if required, notarized or apostilled. During this period, it’s common to have iterative reviews – your advisors will ensure everything meets FSA’s guidelines. This prep phase can take 4–8 weeks or more, depending on readiness.
4. Submission to FSA: The completed application dossier is submitted to the FSA’s Virtual Assets team. This can be done electronically (via email/portal) and by hard copy delivery to FSA’s office in Mahé. The submission must include proof of payment of the application fee. Once submitted, the FSA will formally acknowledge and begin reviewing the application. At this point (if after commencement of law), the company cannot conduct any crypto business until the license is approved. For existing operators who applied before the end of 2024, they may continue operating while FSA reviews the application (under transitional relief).
5. Regulatory Review & Q&A: The FSA will evaluate the application in detail. This due diligence phase typically takes a few months – FSA will verify information, possibly contact references, and assess the business model’s risk. It is common to receive follow-up questions or requests for additional information from the regulator. For example, they might ask for clarification on an AML procedure, more details on an IT security measure, or an in-person meeting with the directors. The applicant must respond to each query comprehensively and in a timely manner (usually within the provided deadline). This stage is essentially an iterative dialogue until FSA is satisfied that all criteria are met. The timeline can stretch if multiple rounds of questions occur.
6. License Approval and Issuance: Once FSA is satisfied, it will issue an approval-in-principle followed by the formal license. At approval-in-principle, they may require final steps like injecting the paid-up capital (if not already done) or verifying the local office setup. Upon fulfilling any final conditions, the FSA will issue the VASP License Certificate and publish the company’s name on the official register of licensed VASPs. The company must then pay the first annual license fee (pro-rated if applicable) to activate the license. The licensee can now legally commence the approved crypto business activities from Seychelles. Congratulations – the process is complete, and operations can begin in the regulated capacity!

Ongoing Maintenance and Compliance Obligations

Obtaining the license is only the beginning – licensed VASPs in Seychelles face continuous obligations to remain in good standing. These ongoing compliance and maintenance requirements include:

• Annual Renewal & Fees: Seychelles VASP licenses are perpetual, meaning they do not expire after a set term. However, to remain valid each year, a licensee must pay the annual license fees and submit a renewal compliance form by January 1. In practice, the annual fee equals the fee paid upon initial licensing (base fee + activity fees). Failure to pay by the deadline or to file the required annual compliance certification is grounds for revocation of the license. Firms should plan ahead to meet renewal deadlines every year and maintain good standing.
• Financial Statements & Audit: Every licensed VASP must prepare audited financial statements annually and submit them to the FSA. The financial year is the calendar year (unless otherwise approved), and audited statements should be filed within a set time after year-end (commonly 3-6 months). The first set of financials may cover up to 18 months if the company was newly incorporated. An approved local auditor must be used. The audit ensures the company is solvent, maintaining required capital, and accurately reporting its finances. The FSA may also require periodic financial condition reports or prudential returns especially if any issues are noted.
• Maintaining Local Substance: The obligations to keep a manned office and resident director are continuous. The FSA expects the licensed company to truly operate from Seychelles. This means the local office should remain active (and not just a mailing address), and the resident director and compliance officers should be actively involved. Material changes like relocating the office or changing the resident director/officers must be notified and typically pre-approved by FSA to ensure compliance is maintained.
• AML/CFT Ongoing Compliance: As a regulated entity, the company becomes a “reporting entity” under Seychelles’ AML/CFT Act. It must implement its AML/CFT program on a day-to-day basis. This includes customer due diligence on all clients, ongoing transaction monitoring, sanctions screening, and filing Suspicious Transaction Reports (STRs) with the Financial Intelligence Unit for any suspicious activities. The firm must also update its Institutional Risk Assessment (IRA) regularly (at least annually or upon major changes) to reflect any new risks or business changes. If the FIU or FSA issues any updated guidance (for example, new high-risk country lists or typologies), the company should incorporate those. Essentially, compliance is an active, ongoing process – not a one-time paperwork exercise.
• Regulatory Reporting: Besides annual financials, the FSA may impose other reporting. For instance, licensees might need to submit quarterly or bi-annual reports on their activities, client numbers, or volume of transactions (the exact reporting requirements are typically set by regulations or license conditions). Also, any significant incidents must be reported – e.g., a major cybersecurity breach or any change that could affect the company’s suitability. Seychelles is implementing a “three lines of governance” model, so the board should ensure internal audit or risk committees periodically review compliance and report internally. The regulator can also conduct inspections or require information on an ad-hoc basis.
• Change Management: If the company wishes to make changes – such as adding a new business activity, changing a director, transferring ownership, or outsourcing a key function – it often needs prior approval or at least notification to the FSA. For example, a change in significant shareholders will trigger a fit-and-proper assessment of the new owners. Likewise, appointing a new compliance officer or MLRO must be reported and the person vetted. All licensed entities should maintain a proactive dialogue with FSA for any corporate changes.
• Consumer Protection and Conduct: Seychelles has a Financial Consumer Protection Act (2022) which applies to VASPs. This means licensed crypto providers must adhere to certain conduct standards: fair marketing, proper disclosures to customers, handling complaints promptly (hence the requirement for a Complaints Handling Policy). The FSA might require periodic reporting on complaints and their resolution. Ensuring customer asset protection (segregating client funds from company funds, as per policy) is also an ongoing duty. These measures are aimed at maintaining trust and integrity in the market.
• Training and Updates: The company should continuously train its staff on compliance, cybersecurity, and operational processes. Regulators often expect that as the business and threat landscape evolves, the company updates its policies and provides refresher training. The compliance officer should stay updated with any changes in law or new guidelines issued by the FSA or international bodies, and update internal procedures accordingly.

In essence, Seychelles expects its licensed crypto firms to operate with the same rigor as other financial institutions. By staying diligent with filings, maintaining capital and substance, and keeping compliance programs effective, a licensee will not only avoid regulatory issues but also benefit from smoother renewals and a good reputation. Non-compliance, on the other hand, can result in penalties or worse – as discussed next.

License Renewal, Suspension, and Revocation

While Seychelles crypto licenses do not expire on a set date (they are continuous), maintaining the license requires annual renewal actions as noted. Each year by January 1, the licensee must pay the renewal fees and file a compliance certification. If these are done, the license remains active for the new year. There isn’t a separate lengthy renewal application; it’s more about certifying ongoing compliance. However, failing to meet renewal obligations (payment and filing) can lead to swift regulatory action. The FSA has made it clear that missing the deadline is a breach that can trigger revocation of the license and even removal of the company from the register. In practice, the FSA would likely give a warning or short grace period, but it has the power to revoke if the licensee is unresponsive.

Beyond renewal logistics, the FSA can suspend or revoke a VASP license if a company seriously violates the laws or no longer meets the criteria. Grounds for suspension/revocation include: breaches of the VASP Act or AML/CFT Act, providing false information to regulators, failure to maintain required capital or a local office, involvement in prohibited activities (like if a licensee was found secretly running a mining operation), or any situation where the FSA believes customers or the financial system are at risk. For example, if a licensee is implicated in facilitating money laundering and does not take corrective action, the FSA could suspend the license while investigating, and ultimately revoke it. The Act also likely provides for revocation if the license was obtained by fraud or if the business is inactive for a prolonged period.

When a suspension or revocation is in play, the FSA will issue a notice to the licensee and possibly a public notice. The company would be required to cease activities (in a suspension, perhaps temporarily until issues are fixed; in revocation, permanently). Notably, operating without a license is a punishable offense – if a company’s license is revoked and it continues business, the FSA can impose fines and seek court orders, including striking the company off the registry or other enforcement. There are provisions for appeal (e.g. an Appeals Board) if a licensee feels a decision was unjust, but the priority is to protect the public and the integrity of the market.

On a more routine note, a licensee can also choose to surrender its license if it decides to wind down the crypto business. In that case, the company would notify FSA, ensure all client assets are properly handled, and then FSA would formally cancel the license. After surrender or revocation, the company could still continue as a non-crypto ordinary business (or be dissolved) but could no longer conduct virtual asset services from Seychelles.

2024–2025 Legal Updates and Developments

The crypto licensing regime in Seychelles is very new, and recent developments have centered on its implementation. Here are the key updates from 2024 and 2025:

• Introduction of the VASP Act (2024): The Virtual Asset Service Providers Act, 2024 was enacted in August 2024 and took effect on 1 September 2024. Upon commencement, all existing crypto businesses in Seychelles had to move toward compliance. The law provided a transition period until 31 December 2024 for those already operating to submit a license application. Companies that filed complete applications by the deadline could continue operating pending FSA’s decision. Those that failed to apply had to cease operations by end of 2024. This transitional grace was a critical update, essentially giving an on-ramp for well-known Seychelles-registered exchanges (like KuCoin, OKX, etc.) to seek licensing. By January 2025, any Seychelles crypto entity without an application in process was considered in breach of law. The Act’s introduction aligns Seychelles with global norms and was positively noted in the industry as closing a regulatory gap.
• Licensing of Major Crypto Firms (2025): In 2025, Seychelles began processing the first batch of VASP license applications. Notably, several major crypto exchanges and brokers received approval-in-principle under the new regime, indicating Seychelles’ attractiveness to big players. For example, OKX (Aux Cayes FinTech Co. Ltd), eToro (Seychelles) Ltd, Bybit (Bybit Technology Ltd), and Bequant were among the early applicants that obtained FSA approval in mid-2025. The FSA’s public register shows these firms in “Status: Assessment” as of mid-late 2025, meaning they are in the final stages of licensing. This is a strong signal that Seychelles is being embraced by established industry players. It also suggests the regulator is actively processing and likely granting licenses to those who meet the criteria. We can expect that by late 2025 or 2026, these companies will be fully licensed and operational under FSA oversight. The presence of name-brand exchanges underscores the credibility of the Seychelles license on the global stage.
• Regulatory Guidance and FAQs: In 2024–2025, the FSA issued detailed guidelines and FAQs to clarify the implementation of the VASP Act. This includes guidance on application contents, capital requirements (through a separate Capital Adequacy Regulations 2024), and ongoing obligations. The FSA has been actively educating stakeholders through FAQs on its website, covering questions like “Who needs a license?”, prohibited activities, how to handle existing clients during transition, etc.. These updates have helped companies understand the new rules and adjust accordingly. Additionally, Seychelles became more engaged in international forums on crypto regulation, signaling its intent to be seen as a reputable, compliant jurisdiction rather than a haven for unchecked activity.
• Future Outlook: As of late 2025, the legal framework is expected to further mature. One anticipated development is the outcome of FATF evaluations – Seychelles’ alignment with FATF standards through the VASP Act will be assessed internationally. Another likely update could be enhancements to the sandbox or innovation programs to foster crypto fintech startups. Also, as the FSA gains experience, it may refine certain requirements or streamline processes (for instance, the timeline might shorten, or specific reporting forms might be introduced). Companies considering Seychelles should stay tuned to any regulatory updates from FSA (the FSA periodically issues circulars or regulatory update notices). So far, the trajectory is positive: Seychelles has moved from an unregulated environment to a fully regulated one in line with global standards within a short span, and early signs (big names applying) suggest the move is paying off.

Official Sources & Primary Legislation (Seychelles)

Primary Acts

• Virtual Asset Service Providers Act, 2024 (Act 12 of 2024) – full text (Official Gazette, 30 Aug 2024).
• Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020 (Act 5 of 2020) – full text.
• Financial Consumer Protection Act, 2022 (Act 6 of 2022) – full text.

Subsidiary Regulations (2024)

• VASP (Capital and other Financial Requirements) Regulations, 2024.
• VASP (Licensing and Ongoing Requirements) Regulations, 2024.
• VASP (Safekeeping and Management of Client’s Assets) Regulations, 2024.
• VASP (Advertisements) Regulations, 2024.

Financial Services Authority (FSA Seychelles)

• VASP Legal Framework – laws, guidance notes, and documents.
• Licensed VASPs Register – public list of licensed/assessed entities.
• VASP Licence Application Guidelines (PDF).
• Submit your application – online submission page.
• VASP FAQs – common questions for applicants and licensees.
• Register of ICO and NFTs – issuer/promoter registration.

Additional Official Resources

• Financial Intelligence Unit (FIU) – VASP Q&A – AML/CFT and transition notes.
• Official Gazette – Bills & Acts (2024) – including VASP Bill No. 12 of 2024.