← Regulations / Philippines / Operating Models / CEX

Centralized exchange in Philippines

Order-book exchange that takes custody of user assets and matches trades between users.

Conditional AI-Generated · Unreviewed

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).

licensing 40% confidence

BSP — VASP licensing, prudential supervision

licensing 40% confidence

SEC Philippines — Securities token oversight, warnings against unlicensed offerings

licensing 40% confidence

AMLC — Anti-Money Laundering Council

licensing 20% confidence

BSP Circular 1108 (2021) — VASP licensing framework

licensing 20% confidence

BSP Circular 944 (2017) — Virtual currency exchange registration

licensing 20% confidence

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.

licensing 20% confidence

CUSTODY: Included under VASP license; IT risk management requirements

licensing 20% confidence

EXCHANGE: VASP license — PHP 50M minimum capitalization. High crypto adoption driven by remittances and gaming/play-to-earn (Axie Infinity).

licensing 20% confidence

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.

licensing 20% confidence

New VASP licenses are frozen indefinitely as of 2025, prioritizing existing licensees.

licensing 20% confidence

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

licensing 20% confidence

Strict compliance with anti-money laundering (AML) procedures is mandatory

licensing 20% confidence

CASPs must submit regular reports to the SEC and the AML Council with detailed documentation 30 days prior to any activity

travel-rule 20% confidence

Travel Rule adopted — threshold: PHP 50,000

travel-rule 40% confidence

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."

travel-rule 40% confidence

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.

travel-rule 40% confidence

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.

travel-rule 40% confidence

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.

enforcement 50% confidence

Violation: Operating without required authorization under the Crypto Asset Service Provider (CASP) framework.

enforcement 50% confidence

Penalty: Geo-blocking; users given 90 days to exit the platform, with website and app access restricted via coordination with telecom providers.

enforcement 50% confidence

Entities: OKX, Bybit, KuCoin, Kraken, MEXC, Bitget, Phemex, CoinEx, BitMart, Poloniex (actively marketing to and serving Filipino users).

enforcement 50% confidence

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.

enforcement 50% confidence

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.

enforcement 50% confidence

Entities: ~50 platforms including Coinbase, Gemini, and overlaps like OKX/Bybit/KuCoin (unlicensed virtual asset service providers/VASPs).

enforcement 50% confidence

Violation: Operating without BSP authorization (BSP Circular No. 1108 for VASP regulations); non-compliance with AMLA via AMLC oversight.

enforcement 50% confidence

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?