Crypto VASP Compliance Self-Assessment

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1a. Regulatory Licenses

Do you hold required licenses/registrations in your operating jurisdictions?

2a. AML/KYC Program

Do you have a functioning AML/KYC program with transaction monitoring?

3a. Customer Fund Protection

Are customer funds segregated and protected? Are funds held directly or via a third-party custodian (e.g., Fireblocks, Anchorage)?

4a. Legal Issues

Any ongoing legal/regulatory proceedings or violations in past 3 years?

5a. Geographic Restrictions

Do you block prohibited jurisdictions (sanctioned countries)?

Geo-blocking enforced via:
6a. Security Framework

Do you follow cybersecurity standards and conduct regular audits?

7a. Management Experience

Do key executives have financial services/compliance experience?

8a. Banking & Key Vendors

Do you have established banking relationships and compliance vendors?

9a. Financial Controls

Are you audited and maintain proper financial controls?

10a. Regulatory Readiness

Are you prepared for upcoming regulatory changes?

Are you in industry groups (e.g., TRM Labs, GBBC, ADGM Sandbox)?

11. Token or Asset Risk Classification

Do you maintain a framework for determining whether an asset is a security or requires regulatory treatment?

12. Disclosures & Transparency

Do you provide public financial or operational disclosures (e.g., proof-of-reserves, attestation reports, risk disclosures)?