Function before labelControl before assumptionRisk before scaleEvidence before conclusionPrivacy by designSecure change managementFunction before labelControl before assumptionRisk before scaleEvidence before conclusionPrivacy by designSecure change management

Global standards · local law · product facts

The dVASP Regulatory Map

There is no single worldwide dVASP classification. Build a service-by-service, entity-by-entity, asset-by-asset, and country-by-country map.

Regulatory mapping is a controlled inventory of legal questions and operating facts—not a table that marks an entire country green or red.

Separate the layers of authority

International standardsCommon terminology and risk-based expectations that countries implement through their own systems.
Binding legislationStatutes and regulations that apply to identified entities, services, assets, and territories.
Regulatory guidanceInterpretations, examples, expectations, and supervisory communications.
Product factsThe transactions, people, entities, control, marketing, and technical architecture to which rules are applied.

Build four linked inventories

  1. Entity inventory: legal entities, foundations, associations, partnerships, service providers, and governance bodies.
  2. Service inventory: custody, exchange, transfer, routing, execution, platform, advice, issuance, administration, or other functions.
  3. Asset inventory: asset rights, issuer, redemption, transferability, classification, chain, wrapper, and supported use.
  4. Country inventory: establishment, people, users, active offering, language, marketing, partners, infrastructure, and payment connections.

Use a question matrix

QuestionOwnerEvidenceDecision output
Which entity provides each service?Legal + productTerms, contracts, flows, operationsEntity/service map
What is the asset?Legal + asset committeeRights, code, issuer, market useClassification and restrictions
Where is the service offered?Legal + commercialUsers, marketing, language, partnersCountry launch matrix
What authorization or registration applies?Local counselLaw, guidance, factual packageLicense path or launch condition
Which controls are required?Compliance + securityRule mapping, architecture, test resultsControl requirements and evidence

Important regional lenses

Global FATF-aligned VASP analysis

Use function, “for or on behalf of another,” people and entities, control or influence, and risk-based controls as a global baseline. Then identify the national implementation that is legally relevant.

United States

Prepare a fact-specific business-model package covering acceptance and transmission, administrators, exchangers, users, hosted and unhosted wallet features, decentralized applications, compensation, and separate federal and state workstreams. Read the U.S. virtual-currency function test.

European Union

Separate the MiCA crypto-asset service provider analysis from VASP terminology and AML/CFT obligations. Classify the asset, map every service, identify the entity, and account for related transfer-information and operational requirements. Read MiCA CASP vs. VASP.

Connect legal decisions to configuration

A country decision should specify the entity, product, services, assets, clients, limits, disclosures, required controls, assumptions, approval date, and change triggers. Product configuration should prevent unsupported combinations from being enabled through a marketing or engineering change.

Never use this map as a legal opinion. It is a workflow for organizing facts, questions, owners, and evidence. Obtain qualified advice for each material launch or change.