Section4(1)(c) of the Proceeds of Crime Act 2015 (Relevant Financial Business)Registration) Regulations 2021 (the “Regulations”) requires that the GFSC maintain a register of relevant financial businesses that are, inter alia,

“undertakings that receive, whether on their own account or on behalf of another person, proceeds in any form from the sale of tokenised digital assets involving the use of DLT or a similar means of recording a digital representation of an asset.”

These are commonly known as Virtual Asset Services Providers (“VASPs” and each a “VASP”).  

Token-sale companies must register as a VASP with the GFSC in order to lawfully sell their digital tokens.  

This involves:

• The drawing up of suitable anti-financial crime and customer due diligence policies and procedures;
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• Appointment of a local head of compliance and MLRO (money laundering reporting officer); and
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• An application to the GFSC.