On-shore VASP in North Macedonia
Locally-incorporated VASP that operates under full local jurisdiction, holding all required licenses and registrations.
On-shore VASP is conditionally permitted in North Macedonia with a local entity, subject to AML obligations and medium licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- Medium
- Last updated
- 2026-07-13
AML Obligations
- Mandatory registration with the Financial Intelligence Unit (FIU) under the Law on Prevention of Money Laundering and Terrorist Financing (LPPMLTF) for all VASPs (exchanges, custody providers, transfer facilitators).
- Full FATF Travel Rule compliance: collect and transmit originator information (name, account number/unique transaction identifier, physical address, national identity number, date/place of birth) and beneficiary information (name, account number/unique transaction identifier) on all VASP-to-VASP transfers with no de minimis threshold.
- Retain Travel Rule and AML records for 5–10 years as per general AML record-keeping rules.
- File suspicious transaction reports (STRs) with the FIU.
- Enhanced due diligence may apply for transactions exceeding certain thresholds (e.g., EUR 1,000 or EUR 15,000 for specific cash/occasional transactions).
- No specific technology mandate for Travel Rule compliance — VASPs may choose their own solution (e.g., TRISA, Sygna).
- Supervised by the Financial Intelligence Unit (FIU / УФР) for AML/CTF compliance.
Key Restrictions
- Cannot be a supervised financial institution (banks, savings houses) — NBRSM has explicitly prohibited supervised entities from dealing in cryptocurrencies.
- Must register with the FIU as a VASP before commencing operations.
- VASP activities defined to include: exchanges between virtual assets and fiat, exchanges between forms of virtual assets, transfers of virtual assets, custody/administration of virtual assets, and participation in financial services related to an issuer's offer/sale of virtual assets.
- Corporate profit tax rate of 10% applies to crypto-related profits; personal capital gains tax rate of 10% also applies to individuals.
- VAT treatment: exchange of crypto for fiat or other crypto is generally exempt; use of crypto to pay for goods/services triggers VAT on the underlying supply.
Key Risks
- Enforcement risk: active criminal investigations and prosecutions by the Ministry of Interior and Financial Police for crypto-related fraud, money laundering, and electricity theft for mining — reputational and legal exposure for operators.
- Regulatory ambiguity: NBRSM maintains that cryptocurrencies are not legal tender and do not fall under its supervision; the legal framework is still evolving with limited formal guidance for licensed VASPs.
- MONEYVAL oversight: North Macedonia is under enhanced follow-up by MONEYVAL, which may drive further regulatory tightening.
- Tax compliance complexity: self-assessment required for crypto capital gains (10%), staking/DeFi yields, airdrops, and mining income — risk of audits by the Public Revenue Office (UJP).
- Limited precedent: no well-established track record of licensed VASP operations; regulatory practice may still be developing.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Law on Prevention of Money Laundering and Terrorist Financing
Regulating Authority: Financial Intelligence Unit (FIU) of North Macedonia (Управата за финансиско разузнавање - УФР) is the primary authority for VASP registration and AML/CTF supervision.
Exchanges (Virtual Asset Service Providers - VASP):
Requirement: Mandatory registration with the Financial Intelligence Unit (FIU) under the LPMALTF.
Scope: This applies to platforms facilitating the exchange of virtual assets for fiat currency, or virtual assets for other virtual assets.
Custody Providers (Virtual Asset Service Providers - VASP):
Adopted: Yes, the FATF Travel Rule (Recommendation 16, as applied to virtual assets) has been adopted in North Macedonia.
Legislation: The primary legislation is the Law on Prevention of Money Laundering and Terrorist Financing (LPPMLTF) (Закон за спречување перење пари и финансирање тероризам).
Key amendments that introduced and refined the virtual asset provisions, including the Travel Rule, were made through various revisions, particularly those in December 2021 (Official Gazette No. 297/21) and subsequent updates.
Effective Date: While the law and its amendments have come into force at different stages, the core virtual asset service provider (VASP) and Travel Rule obligations largely became effective for regulated entities around early 2022. The MONEYVAL 4th Enhanced Follow-Up Report (December 2023) confirms that North Macedonia has addressed the technical compliance deficiencies related to FATF Recommendations 15 (New Technologies) and 16 (Wire Transfers, including VA transfers).
No De Minimis Threshold for VASP-to-VASP Transfers: Consistent with FATF guidance, for transfers of virtual assets between obliged entities (VASPs), there is generally no de minimis threshold for the required originator and beneficiary information to be transmitted. The full Travel Rule information must be collected and transmitted regardless of the amount.
Originator Information: Name, account number (or unique transaction identifier), physical address, national identity number (or customer identification number), date and place of birth (or legal entity registration number for corporate originators).
Beneficiary Information: Name, account number (or unique transaction identifier).
Transmit Required Information: VASPs must obtain and transmit this information to the beneficiary VASP, or to the beneficiary itself if they are using an unhosted wallet.
Retention: VASPs must retain the collected information for a prescribed period (typically 5-10 years, as per general AML record-keeping rules).
No Specific Technology Mandate: Like most jurisdictions, North Macedonia's law does not mandate a specific technical solution (e.g., TRISA, TRAVELER, Sygna). VASPs are expected to choose and implement a solution that allows them to securely and effectively collect, transmit, and store the required information in a compliant manner. The emphasis is on what information needs to be transmitted, not how it is technically done, as long as it meets security and data protection standards.
Administrative Fines: Substantial monetary fines can be imposed on the VASP (legal entity) and/or responsible individuals within the VASP's management. These fines can vary depending on the severity and recurrence of the breach.
Withdrawal of Licenses/Registrations: Supervisory authorities may suspend or revoke a VASP's license or registration if there are serious or repeated breaches of AML/CFT obligations.
Criminal Charges: In cases of severe or intentional non-compliance, particularly if linked to actual money laundering or terrorist financing activities, individuals responsible could face criminal charges and imprisonment.
Corporate Entities: Businesses that engage in cryptocurrency-related activities (e.g., crypto exchanges, payment processors, mining farms, trading firms) will have their profits from these activities included in their overall taxable profit.
Tax Rate: The corporate profit tax rate in North Macedonia is 10%.
Exchange of Cryptocurrency: The exchange of traditional currency for cryptocurrency and vice-versa, or the exchange of one cryptocurrency for another, is generally treated as an exempt financial service. This aligns with the European Court of Justice ruling in the Skatteverket v. David Hedqvist case (C-264/14), which exempted Bitcoin transactions from VAT.
Entity Targeted: General public, financial institutions under NBRSM supervision (banks, savings houses). Violation Type: While not a "violation" in the traditional sense, the NBRSM has consistently warned against the risks associated with cryptocurrencies and explicitly prohibited supervised financial institutions from dealing with them. This sets the regulatory boundary. Penalty Amount: N/A (This is a regulatory warning/stance, not a direct penalty for a specific breach by a regulated entity). Outcome: Heightened public awareness of crypto risks, reinforced prohibition for traditional financial institutions, setting a cautious regulatory tone. The NBRSM maintains that cryptocurrencies are not legal tender and do not fall under its regulatory supervision.
Outcome: Heightened public awareness of crypto risks, reinforced prohibition for traditional financial institutions, setting a cautious regulatory tone. The NBRSM maintains that cryptocurrencies are not legal tender and do not fall under its regulatory supervision.
NBRSM Official Statement (November 2021): https://www.nbrm.mk/ns-newsarticle-soopstenie_za_javnost-23112021.nspx (Macedonian)
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 — an on-shore VASP may operate in North Macedonia subject to mandatory registration with the FIU under the LPPMLTF, full FATF Travel Rule compliance, and applicable tax obligations, but with an evolving regulatory framework and active enforcement risks."
Questions this verdict aims to answer
- What license(s) are required to operate locally?
- What capital, governance, and reporting obligations apply?
- What is the application process and timeline?