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Self-custodial wallet / non-custodial software in San Marino

Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.

No verdict yet

We haven't published a structured verdict for self-custodial wallet in San Marino yet. See the country's topic articles for the underlying regulatory landscape.

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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?