Self-custodial wallet / non-custodial software in Grenada
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is conditionally permitted in Grenada without local incorporation, subject to AML obligations and none licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
Key Restrictions
- No custody of virtual assets — the publisher never holds, controls, or has access to user private keys or funds.
- Software publisher does not fall under the VASP definition under the Virtual Asset Business Act (VABA) because the business does not conduct any of the listed activities (exchange, safekeeping/administration enabling control over virtual assets, transfer, payment services) 'for or on behalf of another natural or legal person'.
- Grenada's VASP licensing framework targets entities that custody or control virtual assets on behalf of others — self-custodial wallet software publishing does not meet this threshold.
Key Risks
- Regulatory ambiguity: while the VASP definition aligns with FATF and likely excludes non-custodial software publishers, no formal guidance or exclusion has been published by GARFIN or the FIU explicitly addressing this category.
- Minor enforcement risk if authorities later interpret 'provision of virtual asset payment services' or 'transfer of virtual assets' broadly to cover the software interface irrespective of custody.
- No consumer-protection or disclosure rules have been identified in the facts that would apply to non-custodial software publishers in Grenada.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Grenada Financial Services Authority (FSA): The competent authority responsible for licensing, supervision, and enforcement of the Virtual Asset Business Act.
Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets.
VASP Definition: The FIU's guidance defines a VASP consistent with FATF recommendations, which includes any natural or legal person who, as a business, conducts one or more of the following activities for or on behalf of another natural or legal person:
Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets. (This explicitly covers custody.)
Virtual Asset Business Act (VABA), 2020: This Act provides the framework for the regulation of virtual asset businesses in Grenada, requiring them to be licensed by GARFIN and comply with AML/CFT requirements.
Require Registration/Licensing: All entities operating as Virtual Asset Service Providers (VASPs) in Grenada are legally required to be licensed by GARFIN and comply with AML/CFT regulations enforced by both GARFIN and the FIU.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a self-custodial wallet software publisher that never holds or controls user private keys is unlikely to be classified as a VASP under Grenada's Virtual Asset Business Act, so no licensing or AML obligations attach, but formal regulatory guidance explicitly excluding such software from the framework has not been published.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?