Self-custodial wallet / non-custodial software in Philippines
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 permitted in Philippines with no licensing burden.
Verdict Details
- Permitted
- yes
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No AML obligations attach to the publisher of self-custodial software because the publisher does not hold, control, or have access to user funds and is not a VASP/MSB under BSP Circular 1108.
- If the software includes integrated on/off-ramp, exchange, or custodial features, those features would trigger VASP licensing and AML obligations under BSP Circular 1108 and AMLA oversight by AMLC.
Key Restrictions
- The software publisher must not hold, control, or have access to user private keys or funds — any custody or control would trigger VASP licensing under BSP Circular 1108.
- The publisher must not offer exchange, on/off-ramp, or financial intermediary services through the software itself without a VASP license.
- If the wallet software is marketed in connection with token offerings that may be securities under Section 3 of the Securities Regulation Code, SEC oversight could apply.
- The software must not include features that would classify it as a Crypto Asset Service Provider (CASP) under SEC Memorandum Circulars No. 4 and No. 5 (July 2025), which would require SEC registration.
Key Risks
- Risk of regulatory creep: BSP or SEC may expand VASP/CASP definitions to cover non-custodial software in the future if enforcement trends continue.
- Enforcement risk if the wallet includes any embedded financial services (staking, swapping, fiat on-ramp) without appropriate licensing — SEC has aggressively targeted unlicensed platforms in 2024-2025.
- Reputational and operational risk if BSP or SEC issues public advisories or geo-blocking orders against the software, as seen with Binance and 50+ platforms in 2024-2025.
- Consumer protection expectations may arise even for non-custodial software under BSP's general consumer protection rules, creating soft-law compliance pressure.
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
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
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
SEC public advisory and enforcement (no specific circular cited; referenced as prior CASP violation): https://bravenewcoin.com/insights/philippines-sec-targets-major-crypto-exchanges-in-regulatory-crackdown
Entity: Binance (world’s largest crypto exchange).
Entities: OKX, Bybit, KuCoin, Kraken, MEXC, Bitget, Phemex, CoinEx, BitMart, Poloniex (actively marketing to and serving Filipino users).
Memorandum Circulars No. 4 and No. 5 (July 2025): https://www.binance.com/en/square/post/27892371667002
BSP request to NTC; BSP Circular No. 1108: https://cryptorank.io/news/feed/17b0b-50-crypto-platforms-targeted-as-philippines-tightens-rules
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.
Yes — publishing self-custodial wallet software in the Philippines does not trigger VASP/CASP licensing or AML obligations, provided the publisher never holds, controls, or accesses user funds/private keys and does not embed exchange, on/off-ramp, or custodial services.
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?