Self-custodial wallet / non-custodial software in Saint Vincent and the Grenadines
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 Saint Vincent and the Grenadines with no licensing burden.
Verdict Details
- Permitted
- yes
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
Key Restrictions
- The publisher does not hold, control, or access user private keys or funds, so the operator does not meet the definition of a VASP under the Virtual Asset Business Act (VABA) and is not subject to VASP licensing requirements.
- No custody of virtual assets means the operator is not a 'reporting entity' for AML/CFT purposes under the AML/CFT Act, 2017 or the Proceeds of Crime Act, 2013.
Key Risks
- If the software is marketed or structured in a way that implies custody, control, or intermediation of user funds, the FSA/FIU could reclassify the operator as a VASP and require registration under VABA.
- False claims of regulatory approval or misrepresentation as a regulated entity have been specifically targeted by SVG enforcement actions.
- Consumer-protection or disclosure obligations (e.g., terms of service, privacy policies) may still apply under general commercial law even though no financial-services regulation is triggered.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
The Proceeds of Crime Act, 2013 (as amended): This act criminalizes money laundering and terrorist financing offenses and provides for the forfeiture of assets derived from criminal conduct.
The Anti-Money Laundering and Combating the Financing of Terrorism Act, 2017 (as amended): This is the principal legislation outlining the obligations for financial institutions and DNFBPs to prevent and detect money laundering and terrorist financing. It defines key terms, outlines reporting obligations, and sets out penalties for non-compliance.
The Financial Intelligence Unit Act, 2001 (as amended): This act establishes the Financial Intelligence Unit (FIU) and defines its powers and functions, including receiving and analyzing suspicious transaction reports.
Obligation to Report: All reporting entities (which would include VASPs if their activities are considered relevant financial business) have a legal obligation to report any transaction (or attempted transaction) where there are reasonable grounds to suspect that funds are the proceeds of criminal activity or are linked to terrorist financing.
Financial Services Authority (FSA):
Financial Intelligence Unit (FIU):
Entity Targeted: General public and entities falsely claiming to be regulated by the SVG FSA for virtual asset business. Violation Type: Operating or advertising virtual asset business activities without proper licensing under the Virtual Asset Business Act, 2020 (VABA), or misrepresenting regulatory status. Penalty Amount: Not applicable to general warnings; specific penalties for unlicensed operation would be determined if an investigation led to a formal enforcement action, which typically isn't publicly detailed. Outcome: Increased public awareness, pressure on unlicensed entities to cease operations or comply, and a clear stance from the regulator.
Entity Targeted: All virtual asset service providers (VASPs) and the general public, including those considering operating in or from SVG. Violation Type: N/A (this is a regulatory clarification, not an enforcement action itself). However, entities failing to register or comply with VABA would be in violation. Penalty Amount: N/A. Outcome: Enhanced clarity on legal obligations for VASPs, driving compliance with registration requirements, AML/CFT measures, and consumer protection. This sets the stage for future enforcement by defining what constitutes a violation.
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.
Yes — a publisher of non-custodial wallet software does not trigger VASP classification under SVG law, as it never holds, controls, or accesses user private keys or funds, and therefore carries no AML obligations and requires no license.
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?