Self-custodial wallet / non-custodial software in Holy See

Exchanges: Entities facilitating the exchange between virtual assets and fiat currencies, or between different forms of virtual assets, would be classified as VASPs.

Custody Providers: Entities providing safekeeping or administration of virtual assets or instruments enabling control over virtual assets would be classified as VASPs.

Payment Processors (dealing with VAs): Entities involved in the transfer of virtual assets or providing services related to the issuance/sale of virtual assets would also fall under the VASP definition.

Decree No. CCCLVI (356) of 19 May 2021, issued by the Secretariat of State (amending Law No. CCXCVII and introducing specific provisions for Virtual Assets and Virtual Asset Service Providers): This crucial decree specifically brought virtual assets and VASPs under the Holy See's AML/CFT regulatory scope, implementing FATF Recommendation 15 and its Interpretive Note. It defines virtual assets and VASPs and subjects them to the same AML/CFT obligations as traditional financial institutions.

Defines "Virtual Asset Service Provider" (VASP) as any natural or legal person who, as a business, conducts one or more of the following activities or operations for or on behalf of another natural or legal person:

Exchange between VAs and fiat currencies.

Exchange between one or more forms of VAs.

Safekeeping and/or administration of VAs or instruments enabling control over VAs.

Participation in and provision of financial services related to an issuer's offer and/or sale of a VA.

Low Cryptocurrency Activity: The Vatican City State is a unique, extremely small sovereign entity with a highly specialized financial system primarily focused on managing the assets of the Catholic Church and its charitable works, as well as supporting its diplomatic missions. It is not a center for commercial cryptocurrency activity or innovation.

Robust AML/CTF Framework: The Holy See has significantly strengthened its anti-money laundering (AML) and counter-terrorist financing (CTF) framework in recent years, under the supervision of its financial intelligence and supervisory authority, the Autorità di Supervisione e Informazione Finanziaria (ASIF). This includes complying with international standards set by the Financial Action Task Force (FATF) and undergoing evaluations by MONEYVAL (the Council of Europe's AML body).

Local Presence: While there isn't a specific "local presence" requirement for external crypto businesses to set up shop (as this is not the Holy See's regulatory focus), any entity operating under its jurisdiction (e.g., Vatican banks or financial institutions) is, by definition, locally present. For foreign entities, the question of "local presence" is generally moot, as the Holy See is not seeking to attract such entities.