Centralized exchange in Philippines
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is conditionally permitted in Philippines with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- VASP license holders must comply with AMLA via AMLC oversight (Anti-Money Laundering Council)
- VASPs must collect and share originator/beneficiary data (name, account/wallet number, physical address, unique ID, date/place of birth) for transactions subject to Travel Rule
- Travel Rule applies at threshold of PHP 50,000
- Sanctions screening against OFAC, UN, EU, and HMT lists required before sending/receiving
- CASPs must submit regular reports to SEC and AMLC with detailed documentation 30 days prior to any activity
- Strict compliance with AML procedures mandatory for SEC-registered CASPs
- SEC fines up to PHP 5 million (~US$88,000) per violation plus daily penalties; BSP may impose license suspension/revocation and potential imprisonment
Key Restrictions
- VASP License from BSP (Circular 1108/2021) required — PHP 50M (~$900K USD) minimum capitalization; 6-12 month licensing timeline
- New VASP licenses frozen indefinitely as of 2025; moratorium partially lifted 2024 but current status is frozen, prioritizing existing licensees
- If operating as a Crypto Asset Service Provider (CASP) under SEC oversight, PHP 100M minimum paid-up capital and physical incorporation in the Philippines required
- 60% Filipino ownership may apply under VASP licensing rules
- Must have a local office and comply with IT risk management and cybersecurity requirements
- Must be geo-blocked if unlicensed — SEC/BSP enforcement against Binance, OKX, Bybit, KuCoin, Kraken, and ~50 other platforms demonstrates active blocking regime
- Stablecoins are permitted but under VASP regime, not as fiat currency
Key Risks
- VASP license moratorium (frozen as of 2025) means new entrants cannot obtain a license, effectively blocking market entry for unlicensed operators
- Aggressive enforcement against unlicensed exchanges — Binance geo-blocked (2024), 10+ major exchanges warned/advisory issued (Aug 2025), ~50 platforms blocked (Dec 2025)
- Dual oversight by BSP (custody/exchange/on-off ramps) and SEC (issuance/marketing/trading/CASP regime) creates regulatory complexity and potential gaps
- FATF Grey List status heightens regulatory scrutiny and travel-rule enforcement pressure
- SEC fines up to PHP 5M per violation plus daily penalties and risk of criminal complaints and website/app blocking via NTC
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
SEC Philippines — Securities token oversight, warnings against unlicensed offerings
BSP Circular 1108 (2021) — VASP licensing framework
BSP Circular 944 (2017) — Virtual currency exchange registration
VASP: VASP License from BSP (Circular 1108/2021). PHP 50M (~$900K USD) minimum capitalization. 6-12 months. BSP imposed moratorium on new VASP licenses in 2022 to assess existing licensees; partially lifted 2024. Coins.ph and PDAX are major licensed operators. 60% Filipino ownership may apply.
CUSTODY: Included under VASP license; IT risk management requirements
EXCHANGE: VASP license — PHP 50M minimum capitalization. High crypto adoption driven by remittances and gaming/play-to-earn (Axie Infinity).
Oversight splits: BSP handles custody, exchanges, on/off-ramps, and payment roles via Circular 1108; Securities and Exchange Commission (SEC) governs issuance, marketing, and trading under its Crypto-Asset Service Provider (CASP) regime.
New VASP licenses are frozen indefinitely as of 2025, prioritizing existing licensees.
Crypto asset service providers (CASPs) must register with the Philippine Securities and Exchange Commission (SEC) and maintain a minimum capital of ₱100 million with physical incorporation in the Philippines
Strict compliance with anti-money laundering (AML) procedures is mandatory
CASPs must submit regular reports to the SEC and the AML Council with detailed documentation 30 days prior to any activity
Travel Rule adopted — threshold: PHP 50,000
Adopted: Yes, via BSP and SEC regulations governing VASPs, as part of efforts to exit the FATF Grey List; described as translating FATF recommendations into national law with a "clear and decisive stance."
Applies to licensed VASPs under BSP and SEC oversight, including those involved in crypto token listings, exchanges (crypto-fiat and crypto-crypto), transfers, issuance/sale of virtual assets, and custodian wallets; requires VASP licensing, capital requirements, and cybersecurity compliance.
VASPs must collect and share originator/beneficiary data (e.g., name, account/wallet number, physical address, unique ID, date/place of birth) for transactions, with sanctions screening against lists like OFAC, UN, EU, and HMT before sending/receiving; interoperability challenges noted globally, but no Philippines-specific protocols detailed.
SEC fines up to ₱5 million (~US$88,000) per violation, plus daily penalties; BSP may impose license suspension/revocation and potential imprisonment; aimed at preventing fraud.
Entity: Binance (world’s largest crypto exchange).
Violation: Operating without required authorization under the Crypto Asset Service Provider (CASP) framework.
Penalty: Geo-blocking; users given 90 days to exit the platform, with website and app access restricted via coordination with telecom providers.
Entities: OKX, Bybit, KuCoin, Kraken, MEXC, Bitget, Phemex, CoinEx, BitMart, Poloniex (actively marketing to and serving Filipino users).
Violation: Operating without SEC licenses/registrations under CASP Rules and Guidelines (Memorandum Circulars No. 4 and No. 5, effective July 2025); providing/soliciting crypto trading services without authorization.
Penalty: Public advisory (August 1-4, 2025); threats of cease-and-desist orders, criminal complaints, website/app blocking via NTC, takedown requests to Google/Meta. Telecoms (PLDT, Smart, Globe) began blocking; list not exhaustive.
Entities: ~50 platforms including Coinbase, Gemini, and overlaps like OKX/Bybit/KuCoin (unlicensed virtual asset service providers/VASPs).
Violation: Operating without BSP authorization (BSP Circular No. 1108 for VASP regulations); non-compliance with AMLA via AMLC oversight.
Penalty: NTC directive to ISPs for website/mobile app blocks (effective by December 25, 2025 via PLDT/Smart/Globe); part of broader risk controls for money laundering/terrorist financing.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a centralized exchange may operate in the Philippines only if licensed as a VASP (BSP Circular 1108, PHP 50M capitalization) and/or registered as a CASP (SEC, PHP 100M capitalization), with a local entity and office; however, the VASP license moratorium (frozen as of 2025) effectively blocks new entrants, and unlicensed operation carries severe enforcement risk (geo-blocking, fines up to PHP 5M, criminal complaints).
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?