The FATF defines a virtual asset service provider (VASP) as: “any natural or legal person who is not covered elsewhere under the Recommendations and 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 virtual assets and fiat currencies

• Exchange between one or more forms of virtual assets

• Transfer of virtual assets

• Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets.

• Participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset. (FATF Updated Guidance on VA & VASP - read our summary).

Financial institutions (FIs) and designated non-financial businesses and professions (DNFBPs) are excluded from this definition.

FATF provides practical guidance to determine whether or not an entity is a VASP; such determination must be done by taking into account the underlying financial services offered, not the entity’s own terminology regarding its activities or the technology used to conduct its activities.