REGULATORY ADVISORY
VASP compliance & regulatory advisory for digital asset businesses.
Aethemis advises virtual asset service providers on licensing, AML and sanctions programs, regulator engagement, and cross-border compliance. Senior-led counsel from former in-house operators and federal regulators.
UNITED STATES
-
EUROPEAN UNION
-
UNITED KINGDOM
-
HONG KONG
-
SINGAPORE
-
UNITED STATES - EUROPEAN UNION - UNITED KINGDOM - HONG KONG - SINGAPORE -
THE PROBLEM
VASP regulation is fragmented. We make it operational.
The regulatory landscape for virtual asset service providers is no longer emerging. It is here, it is fragmented, and it is unforgiving.
Crypto exchanges, custodians, token issuers, and payment providers operating across jurisdictions face overlapping obligations under FATF, FinCEN, NYDFS, MiCA, FCA, SFC, MAS, and the Travel Rule, often simultaneously.
Most firms encounter this complexity in one of three moments: when applying for a license, when responding to a regulator, or when a deal, a launch, or a market entry forces the question. By that point the answers need to be fast, accurate, and commercially aware.
Aethemis advises VASPs through these moments. We work with crypto businesses to scope licensing requirements, design and build compliance programs, engage regulators, and coordinate strategy across the U.S., EU, UK, and APAC.
Our team has built these programs from inside the institutions our clients now operate. We advise the way we used to want to be advised.
WHAT WE DO
How we work with VASPs
Engagements typically fall into one of four service areas. Most clients work with us across several..
-
Licensing strategy and applications
We scope the licensing path for your business, identify the most efficient sequence across jurisdictions, build the application materials, and manage regulator engagement through to authorization.
Our team has worked across BitLicense, U.S. state money transmitter licensing, MiCA CASP authorization, FCA registration, SFC VASP licensing, and MAS payment services licensing. We understand what each regulator actually wants to see, which application questions are technical and which are political, and how to position a business for the smoothest path through.
-
AML, sanctions, and Travel Rule program design
We design and implement AML, sanctions, and Travel Rule programs that meet BSA, MiCA, and FATF standards, and that work operationally inside a real business.
Our compliance build-outs are led by attorneys and former in-house operators with direct experience designing transaction monitoring, customer due diligence, suspicious activity reporting, and Travel Rule infrastructure inside firms like Coinbase. The programs we build hold up under examination because they were built by people who have sat through them.
-
Cross-border regulatory strategy
For VASPs operating in more than one jurisdiction, we coordinate licensing, structuring, and compliance obligations into a single coherent strategy.
Multi-jurisdiction work is the default at Aethemis, not an upsell. We sequence applications efficiently, identify where passporting and reverse solicitation can be used to compress timelines, and make sure the structure in one market does not undermine the position in another.
-
Regulator engagement, examinations, and enforcement
We support clients through supervisory engagement, examinations, information requests, and enforcement matters.
Members of our team have managed these relationships from inside federal agencies, inside in-house counsel functions, and across the table as outside advisors. That perspective changes how we prepare clients for regulator interaction and how we respond when something goes wrong.
WHO WE WORK WITH
Who we advise
Our VASP clients typically include:
Crypto exchanges & trading platforms
Spot, derivatives, and OTC. Licensing, AML, market integrity, and cross-border structure.
Custodians and wallet providers
Custody licensing, segregation requirements, and operational risk frameworks.
Token issuers and stablecoin operators
Issuance structuring, ongoing CASP and VASP obligations, and reserve frameworks
Payment processors and fintechs
Digital asset payment licensing, MSB registration, and Travel Rule compliance.
WHY AETHEMIS
Why VASPs choose Aethemis
Senior-led, always
Engagements are led by partners who have built compliance programs inside the firms our clients are running. No junior hand-offs, no committee dynamics.
Operator experience
Our team integrates former in-house counsel from leading digital asset firms with former federal agents and enforcement attorneys. Clients get one team across law, strategy, and enforcement reality.
Cross-border by default
Multi-jurisdiction strategy is built into how we work. We coordinate the U.S., EU, UK, and APAC under a single engagement.
Practical, fast, and commercially aware.
THE REGULATORY LANDSCAPE WE COVER
Jurisdictions and frameworks we advise on
Aethemis advises VASPs across the regulatory frameworks that matter most to digital asset businesses operating at scale.
United States
FinCEN MSB registration
BSA AML program design
OFAC sanctions
NYDFS BitLicense
U.S. state money transmitter licensing
SEC and CFTC regulatory positioning
Asia Pacific
Hong Kong SFC VASP licensing
Singapore MAS payment services licensing
Cross-border APAC structuring
European Union
MiCA CASP authorization
MiCA passporting and third-country provisions
AMLD and AMLR compliance
National competent authority engagement
United Kingdom
FCA crypto-asset registration
Money Laundering Regulations
UK financial promotions regime
Proposed UK regulatory framework readiness
Global
FATF Recommendation 15
Travel Rule implementation
Cross-jurisdictional counterparty due diligence
ENGAGEMENT MODELS
How engagements work
We work with VASPs on three engagement structures, depending on the situation.
Project-based engagements for defined scopes of work, such as a licensing application, a compliance program build-out, or a market entry analysis.
Retainer advisory for businesses that need ongoing senior counsel on regulatory questions as they arise, without rebuilding context each time.
Specialist matter support for time-sensitive issues such as regulator engagement, examination response, or enforcement matters, where the team needs to mobilize quickly.
Engagements begin with a consultation to scope the matter, identify the right team members, and define the structure that fits.
FAQS
Frequently asked questions
-
It depends on the activity, not the label. If your business exchanges, transfers, custodies, issues, or administers virtual assets on behalf of customers, it is likely a VASP under FATF standards and will trigger licensing or registration requirements in most major jurisdictions. Whether your specific activities require a license, and which one, depends on what you do, where you do it, and who your customers are. The right starting point is a regulatory scoping analysis.
-
VASP (Virtual Asset Service Provider) is the FATF term used globally. CASP (Crypto-Asset Service Provider) is the EU's equivalent term under MiCA. The activities covered are substantially similar but the authorization process, prudential requirements, and supervisory framework differ.
-
Generally, yes, if your activity meets the licensing threshold in that jurisdiction. Some frameworks (notably MiCA) include passporting mechanisms that extend authorization across regional blocs. Others (such as U.S. state MTLs) require separate licensing in each state. Cross-border strategy is about sequencing and coordinating these efficiently.
-
It varies. The application process is usually less of a constraint than the operational and compliance build-out required to support it. We help clients sequence both in parallel to compress the overall timeline.
-
Yes. A significant portion of our VASP work involves clients who are already mid-application, mid-examination, or mid-enforcement. We can step in at any stage and have done so across all four engagement types.
-
Cost depends on the scope, jurisdictions, and engagement structure. We are a senior-led firm and we are not a low-cost option. We are usually the right choice for businesses where the regulatory question carries strategic or financial weight and the cost of getting it wrong is significantly higher than the cost of getting it right.
Speak with a VASP regulatory advisor
Whether you are scoping a new license, building a compliance program, or preparing for regulator engagement, we should talk.