Seychelles Crypto Regulation 2025 – A Practitioner’s Guide for VASPs

1) Why Seychelles, and what has changed?

Seychelles has moved decisively from “policy intent” to a fully–fledged licensing regime for Virtual Asset Service Providers (VASPs). The Financial Services Authority (FSA) is now the prudential and conduct regulator for VASPs under the Virtual Asset Service Providers Act, 2024 (Act 12 of 2024), supplemented by detailed regulations on licensing, capital, advertising, cybersecurity, safekeeping/asset management, and ICO/NFT registration. The Act provided a short transitional runway that required existing operators to regularize by 31 December 2024; from 2025, Seychelles is a straight licensing jurisdiction – no “wait-and-see” exemptions.

2) Who regulates & the legal framework

Regulator: Financial Services Authority (FSA), Victoria, Mahé. The FSA also issues VASP Licence Application Guidelines (latest version September 2, 2024), which explain scope, process, and supervisory expectations.

Core instruments (non-exhaustive):

• VASP Act, 2024 (Act 12 of 2024), incl. Schedules on fees and substance; includes consequential AML/CFT amendments.
• VASP (Licensing & Ongoing Requirements) Regulations, 2024 (sets application content and continuing duties).
• VASP (Capital & Other Financial Requirements) Regulations, 2024.
• VASP (Advertisements) Regulations, 2024.
• VASP (Cyber Security Requirements) Regulations, 2024. (referenced alongside licensing duties).
• Asset Service Provider (Safekeeping & Management of Client Assets) Regulations, 2024.
• VASP (Registration of ICOs and NFTs) Regulations, 2024.
• VASP Licence Application Guidelines (FSA).

3) What activities are regulated?

The Act’s First Schedule defines the regulated Virtual Asset Services. At a high level:

1. Virtual Asset Wallet Providers: custodial & non-custodial services including transfer, safekeeping and management of virtual assets/ICOs/NFTs for clients.
2. Virtual Asset Exchanges: transfer, conversion, and exchange between VAs/ICOs/NFTs and/or fiat for clients.
3. Virtual Asset Broking: intermediary/facilitation through exchanges and wallet providers (including facilitation of safekeeping).
4. Virtual Asset Investment Providers: portfolio management of VAs/ICOs/NFTs and investment advice on the same.

Prohibitions. Seychelles explicitly prohibits: (i) natural persons operating VASP businesses; and (ii) operating mining facilities or mixers/tumblers in or from Seychelles.

4) Marketing crypto services in Seychelles (what “good” looks like)

Marketing is tightly managed by the VASP (Advertisements) Regulations, 2024. A VASP must ensure advertisements are accurate, balanced, not misleading; must keep records of ads and notify the Authority in accordance with the Regulations; and must ensure that overseas or third-party promoters also meet local standards. The Regulations apply to broadcast, print, online, and in-app promotions.

Practical tips for campaigns:

• Prominent, plain-language risk warnings; no suggestion of guaranteed returns.
• Clear target-market statement; avoid indiscriminate retail push.
• Record-keeping of all creatives, targeting parameters, and performance copies.

5) Paid-up capital and licence fees

Capital (minimum paid-up): (Part 1 of Schedule to Capital Regulations – new applicants)

• Wallet Providers: USD 75,000
• Exchanges: USD 100,000
• Brokers: USD 50,000
• Investment Providers: USD 25,000

Plus: by the beginning of Year 3, maintain 2.5% of annual turnover (proof at payment of the third annual licence fee).

Statutory fees (Second Schedule to the Act):

• Application fee (licence): SCR 75,000; application for registration: SCR 22,500.
• Annual licence (base + by activity): e.g., Wallet: SCR 75,000; Exchange: SCR 300,000; Broking: SCR 150,000; Investment Provider: SCR 75,000.
• Miscellaneous: fee for fit-and-proper determination, register inspection, certified copy, etc.

6) Mandatory licensing requirements (people, presence & prudence)

Fit & Proper & Governance. Applicants must meet fit and proper standards for controllers and senior management and appoint key control roles (Compliance, AML, Risk, and Audit as applicable under the licensing and ongoing requirements). The Guidelines emphasize that the FSA may reject incomplete or inaccurate submissions and bars resubmission for six months after rejection.

Substance in Seychelles (Third Schedule – Act). Every licensee must:

• Have at least one resident director;
• Operate a fully manned local office with qualified staff and accessible records;
• Handle complaints in Seychelles;
• Hold at least two board meetings and four management meetings in Seychelles annually.

Record-keeping & Audit. Daily books and records, kept in original digital form for 7 years, to IFRS/recognised standards; auditor reporting duties and escalation to FSA within 7 days for deficiencies.

Prohibitions recap. No natural-person VASPs; no mining/mixers/tumblers.

7) Application procedure (what to expect)

Step 1 – Pre-filing diagnostics. Confirm activity mapping to one or more of the four VASP categories; confirm capitalization and substance plan (resident director, office, staffing).

Step 2 – Assemble the application. The Licensing & Ongoing Requirements Regulations (Schedule) specify the core dossier, including:

• Constitution/incorporation documents, ownership & group charts;
• Business plan and risk assessment (incl. outsourcing, technology stack);
• AML/CFT & CPF frameworks (policies, CDD/EDD, sanctions, Travel Rule);
• Cybersecurity policies, incident response, and controls;
• Safekeeping/asset segregation model where applicable;
• Key persons’ fit-and-proper files;
• Financials, capital confirmation, auditor consent;
• Complaint handling and financial consumer protection arrangements.

Step 3 – File with FSA. Pay the application fee and submit via the FSA process with all appendices and declarations in the Application Guidelines. Accuracy matters: outdated or inconsistent documents will see the file deemed incomplete and refused (with fee forfeited).

Step 4 – Queries & approvals. Expect supervisory questions on governance, AML/CPF controls, tech resilience, wallet architecture, and custody arrangements (if relevant). On approval, pay an annual licence fee by activity.

8) Documents required (checklist starter)

While the precise list varies by business model, be ready with:

• Corporate: incorporation docs, registers, share certificates, group chart;
• People: CVs, certified IDs, police clearances, references, matrices of roles/responsibilities;
• Governance: Board & committee terms, policies (compliance, risk, audit);
• AML/CFT/CPF: full policy suite, KYC/CDD/EDD playbooks, sanctions screening, STR reporting, Travel Rule controls;
• Technology: architecture diagrams, cybersecurity program, BCP/DR;
• Financials: capital proof, 3-year financial projections, auditor engagement;
• Business plan: products, markets, client types, marketing plan consistent with Advertisements Regulations.

9) Ongoing compliance: AML/Travel Rule, cybersecurity, client assets

1. AML/Travel Rule. The Act amends the AML/CFT law to embed Travel Rule-style obligations on originator and beneficiary VASPs, including collection, verification and secure transmission of originator/beneficiary details and record-keeping (with special handling for batch and straight-through transfers). No simplified due diligence is permitted for VASP customers. Seychelles also sets a reporting threshold for transfers of SCR 50,000 (or more) and brings SCR 15,000 transfer triggers into the AML framework.
2. Cybersecurity. Applicants must maintain robust information-security governance, incident detection/response and resilience as prescribed by the Cyber Security Requirements and the licensing regulations; regulators will focus on breach handling and wallet key-management controls.
3. Safekeeping & asset segregation. Where you hold client assets, you must meet the Safekeeping and Management rules – clear segregation, reconciliations, and custody controls.
4. Books and audits. Keep daily records, preserve them for 7 years, and ensure auditor escalation to the FSA within 7 days if record-keeping falls short.
5. Marketing conduct. Maintain an approvals log for all ads, ensure fair-balance, and align with the Advertisements Regulations (including online).

10) Timelines & practicalities

Timelines vary with readiness and the volume/complexity of supervisory queries. A realistic planning window for a well-prepared file is typically several months from submission to grant (longer if tech-heavy models or custody are involved), with key gating items being substance, capital, and AML/Travel Rule readiness. (The six-month cooling-off period after a rejection underscores the value of pre-filing due diligence.)

11) How CRYPTOVERSE Legal helps

• Regulatory strategy & scoping. We translate your product into the correct Seychelles permissions (Wallet/Exchange/Broking/Investment Provider) and calibrate paid-up capital and fee exposures.
  
• Application build-out. We craft your business plan, governance pack, AML/CFT and Travel Rule playbooks, cybersecurity program, and advertising controls aligned to the FSA’s schedules and guidelines.
  
• Substance solutions. We help seat a resident director, stand up a fully manned office, and schedule board/management cadences to meet Third Schedule substance.
  
• Ongoing compliance. We operationalize record-keeping, audit, client-asset segregation, cybersecurity, and marketing controls – so you remain exam-ready.

Final word (disclaimer)

This article is a high-level guide. It references statutory and regulatory sources current to 2025 but is not legal advice. Specific structuring choices, product design, and marketing approaches can materially alter your licensing path and obligations. Engage counsel early.

Key references (by provision)

• Act 12 of 2024 – First/Second/Third Schedules (activities, fees, substance); AML/CFT amendments embedding Travel Rule and thresholds.
• Capital Regulations, 2024 – minimum paid-up capital; record-keeping and auditor duties.
• Licensing & Ongoing Requirements, 2024 – application content/continuing obligations.
• Advertisements Regulations, 2024 – fair, accurate, documented marketing.
• FSA Guidelines (2 Sept 2024) – process clarifications; cooling-off after rejection; prohibitions on natural-person VASPs, mining/mixing.

Disclaimer: 

This article is for general information only and does not constitute legal advice. Regulatory thresholds, fees, and supervisory practices change via circulars and amendments. For tailored counsel and filings, engage CRYPTOVERSE Legal.