Crypto funding compliance for brokers in Vanuatu
Vanuatu Financial Services Commission (VFSC) · Financial Dealers Licence (FDL)
The fastest entry point into licensed brokerage, which makes your own evidence matter more.
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The Financial Dealers Licence after the 2021 reformsThe quickest and cheapest licence to obtain, made more substantial by residency requirements, higher capital and closer VFSC attention.
Vanuatu's Financial Dealers Licence remains the quickest and cheapest route to a licensed brokerage, and reforms since 2021 (residency requirements, higher capital, closer VFSC attention) have made it more substantial than its early reputation. AML obligations apply under the Anti-Money Laundering and Counter-Terrorism Financing Act No. 13 of 2014. That Act contains no express reference to virtual assets, so do not build a crypto control framework on it alone.
Many FDL brokers accept crypto funding as a core feature, often more centrally than brokers in any other jurisdiction on this list.
Two digital-asset regimes, both using "Class D"The FDL's Class D came in 2021. The separate Virtual Assets Service Providers Act followed in 2025, and the VFSC has said FDL holders are not permitted to operate as VASPs.
The 2021 amendment to the Financial Dealers Licensing Act added a Class D Principal's Licence for dealing in digital assets, defined as an immaterial asset in digital form stored on a distributed ledger and representing a set of rights or values. Under the VFSC's guidance, only existing Class A, B or C holders may apply for it. That provision is still in the Act.
In 2025 Vanuatu passed a separate Virtual Assets Service Providers Act, with its own class D, D.1, D.2, D.3 and D.4 licences for exchange, transfer, custody, issuer-related financial services and bank exchange-plus-custody. It does not repeal the FDL's Class D, so two regimes now coexist and both use the letter D. That overlap makes it easy for a broker to hold the wrong licence without realising it.
The VFSC's 2025 risk assessment for virtual assets is more direct than either statute. It states that the existing law does not allow firms providing company services or securities and other investment services, FDL holders included, to operate as VASPs. If what you do with client crypto looks like a virtual-asset service, read the 2025 Act first and treat the FDL Class D as the narrower licence. Take this to Vanuatu counsel. It is an open question, not a formality.
Counterparty scrutiny of a light-touch licenceA light-touch licence means every counterparty compensates with extra scrutiny, so you have to be able to produce the evidence yourself.
Because the licence is light-touch, every other counterparty (banks, PSPs, liquidity providers, even the payment processors themselves) applies extra scrutiny to compensate. A Vanuatu broker is asked to prove its controls more often than a Cypriot one, because the licence proves less. Screening records you can produce in minutes, with integrity a third party can verify, are the difference between keeping banking relationships and losing them.
This is arguably where KYTGate is most useful. It produces independent, cryptographically signed evidence of disciplined crypto-funding controls automatically on every deposit, which gives a broker credibility the licence alone does not.
Questions brokers ask about Vanuatu
Does the Vanuatu VFSC allow FDL brokers to accept crypto deposits?
The Financial Dealers Licensing Act does have a Class D Principal's Licence for dealing in digital assets, added in 2021, and many FDL brokers accept crypto funding as a core feature. But Vanuatu also passed a separate Virtual Assets Service Providers Act in 2025 with its own licence classes, and the VFSC's 2025 risk assessment states that existing FDL holders are not permitted to operate as VASPs. So the answer depends on whether what you do with client crypto is dealing under your FDL class or a virtual-asset service under the 2025 Act. This needs Vanuatu counsel, not just a reading of the class list.
Which rules apply to crypto funding for a Vanuatu broker?
The Financial Dealers Licensing Act and VFSC conditions for the licence, the Virtual Assets Service Providers Act No. 3 of 2025 if any part of the activity is a virtual-asset service, the Anti-Money Laundering and Counter-Terrorism Financing Act No. 13 of 2014 and regulations (due diligence, monitoring, record-keeping, reporting to the FIU), and Vanuatu's sanctions framework. Note that the 2014 AML Act makes no express provision for virtual assets, so your crypto controls have to be built on the licence conditions and the 2025 Act rather than inferred from it. A light-touch licence does not lighten the AML obligations.
What evidence do the VFSC and everyone else expect?
The VFSC expects an AML programme and can inspect it. In practice a Vanuatu broker is asked to prove its controls more often by banks, PSPs, liquidity providers and payment processors, precisely because the licence proves less. Screening records you can produce in minutes, with integrity a third party can verify, are what keep those relationships.
What is the Travel Rule status in Vanuatu?
Vanuatu now has a Virtual Assets Service Providers Act (No. 3 of 2025), so the framework is no longer absent, but Travel Rule obligations for a broker that uses a processor rather than holding a VASP licence itself are not clearly settled. Treat originator and beneficiary data your processor hands over as something to keep, and check with counsel on what is required of your structure.
What does KYTGate provide for a Vanuatu broker?
Independent, cryptographically signed evidence of disciplined crypto-funding controls, produced automatically on every deposit: credibility the licence alone does not confer. Processor KYT results, Travel Rule data and your own decisions are recorded next to official sanctions data and live issuer freeze reads, and the evidence pack is what you hand to a counterparty's compliance team.
General information, not legal advice. Where an answer says to check with counsel, the point depends on your structure and needs a lawyer's view.
Sources
Official documents only: the regulator, the FIU, a government legislation portal or an official law-report site. We read each one before citing it here. Where a document is dated or superseded, the note says so.
- Financial Dealers Licensing Act [CAP. 70], Consolidated Edition 2026 · VFSCClasses A to D, and section 2(1)(ad) on dealing in digital assets under a Class D Principal's Licence. Take the 2026 consolidation: the 2018 edition still on the site predates Class D.
- Virtual Assets Service Providers Act No. 3 of 2025 · VFSCThe separate VASP regime, with its own class D, D.1, D.2, D.3 and D.4 licences at section 11. It contains no provision repealing the FDL's Class D.
- Risk Assessment for Virtual Asset Service Providers and Issuers of Initial Token Offerings in Vanuatu (November 2025) · VFSCWhere the VFSC states that existing FDL and company-services licensees are not permitted to operate as VASPs. Read this before assuming Class D covers what you do.
- Guidelines on Digital Assets · VFSC Supervision DepartmentThe VFSC's guidance on the Class D licence introduced by the Financial Dealers Licensing (Amendment) Act No. 9 of 2021, including that only Class A, B or C holders may apply for it.
- Anti-Money Laundering and Counter-Terrorism Financing Act No. 13 of 2014 · VFSCThe AML statute: FIU, reporting-entity registration, CDD, record-keeping, reporting and the AML/CTF programme. It makes no express provision for virtual assets.
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