In November 2025 the BVI Financial Services Commission (FSC) released Circular 43, which includes a helpful FAQ document called "Understanding Virtual Assets and VASP Regulation".
Think of it as your go-to guide for navigating the regulatory requirements around virtual asset activities under the Virtual Assets Service Providers Act, 2022 (VASP Act), which has been in effect since 1 February 2023.

Let's break down the key points from the guidance:

What counts as a virtual asset?

Simply put, virtual assets are digital representations of value that you can use for trading, making payments, or investing – but this doesn't include traditional fiat currencies.

What activities does this cover?

If you're running exchanges, handling transfers, providing safekeeping services, or offering financial services related to virtual assets, you're likely operating as a VASP.

What do you need to do to stay compliant?

There are three main requirements:

• Register with the FSC – this isn't optional.
• Follow Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) regulations – these are critical safeguards.
• Appoint Compliance Officers and maintain robust internal controls – you need the right people and systems in place.

What happens if you do not comply?

Operating without proper registration is potentially a criminal offence and can land you with fines of up to US$100,000 or even imprisonment. The FSC isn't messing about here.

The FSC is emphasising compliance for good reason – it's all about mitigating risks like money laundering and terrorist financing and protecting the integrity of the BVI's financial system. Whether you're already operating in this space or considering entering it, understanding these requirements is essential.

For the full details, you can access Circular 43 and the FAQs directly from the FSC.

Need help navigating VASP regulations in the BVI? Get in touch with our team for tailored guidance.

For more details, access Circular 43 here and the FAQs here.