On-shore VASP in Taiwan
Locally-incorporated VASP that operates under full local jurisdiction, holding all required licenses and registrations.
On-shore VASP is conditionally permitted in Taiwan 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
- VASP registration with FSC required before operating
- Implement AML/CTF internal control systems per the Regulations Governing Anti-Money Laundering and Countering Terrorism Financing for Virtual Asset Service Providers (effective July 1, 2021)
- Conduct customer due diligence (CDD) measures
- Report suspicious transactions to FSC
- Travel Rule compliance — threshold: TWD 50,000 per transaction
- Establish internal control and audit systems including 'measures for safeguarding virtual assets' (Article 11, VASP AML Regulations)
- Maintain proper record-keeping for all transactions
- Subject to FSC oversight and supervision
Key Restrictions
- Must be locally incorporated in Taiwan
- Must register as a VASP with the FSC under current Guiding Principles (formal VASP Act under legislative review, expected 2025-2026)
- Customer asset segregation required under FSC guidelines
- Information security management required for exchanges
- Stablecoin framework under development — no finalized rules yet
Key Risks
- Dedicated VASP legislation still in legislative review (expected 2025-2026) — regulatory regime may shift significantly
- Enforcement precedent: ACE Exchange founder arrested for fraud/money laundering (2024); ongoing crackdowns on unregistered crypto schemes
- Tax framework for crypto is piecemeal (gains treated as 'other income' under Income Tax Act); specific crypto tax legislation under development
- No specific digital asset custody license exists yet — custody falls under VASP AML registration, creating ambiguity
- No explicit regulatory mandate for insurance/bonding on custodial assets at present
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
VASP: VASP Registration under FSC guidelines (3-6 months). Dedicated VASP law under legislative review. Approach influenced by Japan and Singapore models. MaiCoin and BitoPro are major local players.
FSC — VASP guidelines and oversight — dedicated law under legislative review
FSC Guidelines and Oversight: The FSC issues guidance (e.g., VASP Application Guidance, AML/CFT Notes, Travel Rule Guidance) and FAQs (latest published November 21, 2025) covering VASP definitions, registration, compliance obligations like AML/CFT systems, audits, and record-keeping, plus supervisory powers including enforcement and risk-based monitoring.
Registration and Status: Over 16 VASPs have been approved since March 2024, with the FSC committing to initial feedback within 6 weeks and decisions within 6 months, though actual timelines vary.
CUSTODY: Customer asset segregation required under FSC guidelines
EXCHANGE: VASP registration with FSC; information security management required. Self-regulatory organizations among exchanges. Stablecoin framework under development.
Guiding Principles for Management of Virtual Asset Service Providers (2023) — VASP registration and conduct guidelines (being formalized into law, expected 2025-2026)
Financial Supervisory Commission (FSC): The primary financial regulator in Taiwan responsible for overseeing financial institutions and has extended its oversight to VASPs regarding AML/CTF.
Regulations Governing Anti-Money Laundering and Countering Terrorism Financing for Virtual Asset Service Providers (虛擬通貨平台及交易業務事業防制洗錢及打擊資恐辦法)
Issued by the FSC, effective July 1, 2021.
These regulations require VASPs to implement robust internal control systems for AML/CTF, report suspicious transactions, and conduct due diligence.
Segregation of Client Assets Rules:
Custodial License Requirements:
Comprehensive VASP Special Law: The FSC has publicly announced its intention to establish a dedicated and comprehensive regulatory framework for virtual assets, moving beyond just AML/CTF.
Travel Rule adopted — threshold: TWD 50,000
Evidence fact tw.tax not found (may have been renamed).
Gains from the sale of cryptocurrencies are considered "Other Income" (其他所得) under Article 14 of the Income Tax Act.
Entity Targeted: David Pan (潘奕hofer), founder of ACE Exchange, and approximately 10 other individuals. Violation Type: Fraud, money laundering, operating an illegal pyramid scheme, organized crime. The group allegedly used fake tokens (NFTC, MOCT) to defraud investors out of hundreds of millions of New Taiwan Dollars. Penalty Amount: Assets worth over NT$200 million (approximately US$6.4 million) were frozen, including real estate, luxury cars, and cryptocurrency. The investigation is ongoing, and final penalties (imprisonment, further asset forfeiture) will be determined by the courts. Outcome: Key individuals, including the founder of a prominent Taiwanese exchange, were arrested. Assets were frozen, and legal proceedings are underway. This was a major blow to investor confidence and highlighted the risks within the unregulated parts of the crypto market.
Entity Targeted: Numerous individuals and groups promoting "Pi Network" as a guaranteed high-return investment or operating multi-level marketing (MLM) schemes based on its unlisted cryptocurrency. Violation Type: Fraud, operating illegal pyramid schemes (violation of the Multi-level Marketing Supervision Act), misleading advertising. Penalty Amount: Varies per case, but includes arrests, asset seizures (though often smaller sums of cash, not directly crypto), and fines/imprisonment upon conviction. Specific aggregate amounts for all Pi Network-related crackdowns are hard to tally as they are localized efforts. Outcome: Numerous arrests across Taiwan, public warnings issued by authorities regarding the risks of Pi Network and similar speculative "investments," helping to protect potential victims.
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 — a locally-incorporated on-shore VASP may operate in Taiwan by registering as a VASP with the FSC (3-6 month process), complying with AML/CTF regulations including Travel Rule (TWD 50k threshold), and meeting asset segregation and information security requirements, though a dedicated VASP Act is still under legislative review and expected to impose fuller obligations by 2025-2026.
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?