Our Proposal
A two-jurisdiction pathway for virtual asset operations
A comprehensive proposal for the establishment and licensing of a Virtual Asset Service Provider (VASP) across two jurisdictions: the Seychelles (FSA VASP licence) and Canada (FINTRAC MSB registration with virtual currency services). Each jurisdiction is addressed separately with full regulatory scope, fee schedules, and operational requirements.
A regulated virtual asset presence across two strategic jurisdictions.
This proposal, prepared by Fintech & Innovation Ltd (FIL), covers the end-to-end setup and licensing of a virtual asset services business across the Seychelles and Canada. Both jurisdictions provide distinct commercial and regulatory advantages for crypto-focused businesses seeking international credibility, client onboarding flexibility, and operational legitimacy.
Seychelles VASP provides a fully regulated licence under the FSA VASP Act 2024 — covering exchange, wallet, custody, brokerage, advisory, and token offering activities. It is one of the most comprehensive and cost-effective virtual asset licensing regimes globally, with clear capital requirements and a defined approval pathway. Privacy-enhancing services (mixers, tumblers) are explicitly prohibited.
Canada MSB provides a FINTRAC registration that authorises virtual currency exchange and transfer services. Canada is a G7 jurisdiction with a well-developed AML/CFT framework, making a Canadian MSB registration highly credible for banking relationships, institutional partnerships, and client onboarding in North America and beyond. Registration (not a licence) means no capital requirement and a faster process.
Regulatory framework, requirements, and timelines for each jurisdiction.
Seychelles — FSA Virtual Asset Service Provider Licence
- Regulator
- Financial Services Authority (FSA), Seychelles
- Governing law
- Virtual Asset Service Providers Act, 2024
- Entity required
- Seychelles company or International Business Company (IBC) — only companies/IBCs eligible; natural persons ineligible
- FATF status
- Not currently on FATF grey list (delisted October 2023)
- Capital requirement
- Set by FSA per activity — Exchange USD 100,000 / Custody-Wallet USD 75,000 / Broker USD 50,000 / Advisory USD 25,000
- Year 1 total cost
- Activity-dependent — see fee schedule below
- Estimated timeline
- 6 to 8 months end-to-end (depending on FSA review)
Scoping & entity selection
Confirm VASP licence class(es), incorporate Seychelles company, appoint resident director and MLRO
Documentation preparation
Business plan, AML/CFT policy, compliance manual, cybersecurity policy, 3-year financial projections
Banking and capital
Open local bank or EMI account; deposit minimum paid-up capital per selected licence class
FSA application submission
Submit complete VASP licence application and supporting documents to the Financial Services Authority
FSA review and queries
FSA due diligence, fitness and propriety checks; clarification rounds typically 3 to 5 months
Licence issuance and post-activation
Travel Rule setup, first compliance filings, staff training, ongoing reporting systems
VASP licence classes available
| Class | Activity | Min. Capital | Govt Application Fee | Annual Licence Fee |
|---|---|---|---|---|
| Exchange Services | Crypto-fiat and crypto-crypto exchange platforms | USD 100,000 | USD 5,500 | USD 27,500 |
| Custody / Wallet | Safekeeping, administration and management of virtual assets or private keys | USD 75,000 | USD 5,500 | USD 22,000 |
| Broker / Dealer | Intermediary, market maker between buyers and sellers | USD 50,000 | USD 5,500 | USD 11,000 |
| Advisory / Portfolio | Investment advice, portfolio management, research on virtual assets | USD 25,000 | USD 5,500 | USD 5,500 |
| Transfer Services | Transfer or transmission of virtual assets between addresses on behalf of clients | Per FSA | USD 5,500 | Per FSA |
| Token Offerings (IITO) | Issuance, offering or selling of tokens; ICO/IITO participation; separate registration required | Per FSA | USD 5,500 | Per FSA |
| ATM / Kiosk | Installation or operation of crypto ATMs converting virtual assets to fiat | Per FSA | USD 5,500 | Per FSA |
KYC and document requirements
Fee schedule — Seychelles VASP Licence (FIL professional fees included)
| Service | USD | Frequency | Notes |
|---|---|---|---|
| FIL professional fee (all-inclusive licence application) | |||
| End-to-end VASP licence application Consultation, entity selection, company incorporation, registered office (Year 1), full application pack (business plan, AML/CFT manual, compliance manual, cybersecurity policy, financial projections), FSA liaison, post-submission query management |
USD 48,000 | One-off | Payable in milestones: 60% on contract signing, 35% on FSA application approval, 5% on licence issuance |
| Year 1 additional fees | |||
| Local Secretary (Year 1) Mandatory for FSA compliance |
USD 4,500 | One-off | Charged in first invoice alongside 50% professional fee |
| Bank account opening introduction | USD 3,000 | On incorporation | Payable once company is incorporated |
| Government fees (payable to FSA — non-refundable) | |||
| FSA licence application fee (all classes) | USD 5,500 | One-off | Payable on submission of licence application |
| Annual FSA licence fee Varies by class: Exchange USD 27,500 / Custody USD 22,000 / Broker USD 11,000 / Advisory USD 5,500 |
USD 5,500 to USD 27,500 |
Annual | Payable once licence is approved; amount depends on class selected |
| Annual recurring fees (Year 2 onwards) | |||
| Local Secretary (Year 2+) | USD 6,000 | Annual | Revised annual rate |
| Annual Return Filing | USD 500 | Annual | Statutory annual return to Seychelles Registrar |
| Mandatory operational costs (post-licence, monthly) | |||
| Local Director (mandatory once licensed) | USD 4,500/month | Monthly | FSA substance requirement: resident director actively involved in governance |
| 1x Operational Staff — salary | USD 2,000/month | Monthly | Mandatory once licensed |
| 1x Compliance Officer / MLRO — salary | USD 3,500–5,000/month | Monthly | Must be resident, approved by FSA; salary subject to negotiation |
| Office space (2-seater minimum) | USD 1,000/month | Monthly | Physical office required; mailbox address not accepted |
| Bookkeeping / Accountant | USD 1,000/month | Monthly | Ongoing accounting and record-keeping |
| Total monthly operational costs (once licensed) USD 12,000 / month | Director USD 4,500 + Operational Staff USD 2,000 + Compliance Officer USD 3,500 + Office USD 1,000 + Bookkeeping USD 1,000 | ||
Canada — FINTRAC MSB Registration (Virtual Currency Services)
- Regulator
- Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
- Governing law
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA); FINTRAC MSB Regulations
- Registration type
- Federal MSB registration (not a licence) — no minimum capital requirement
- FATF status
- FATF member in good standing; G7 jurisdiction; high credibility globally
- Virtual currency services covered
- Virtual currency exchange (crypto-fiat and crypto-crypto) and virtual currency transfer services
- Year 1 total cost
- See fee schedule below
- Estimated timeline
- 6 to 8 months end-to-end (including entity setup, documentation, and FINTRAC processing)
Entity incorporation and scoping
Incorporate Canadian entity (federally or provincially); determine VC service scope and AML/CFT programme requirements
AML/CFT programme and policies
Develop AML/CFT compliance programme, KYC/CDD procedures, suspicious transaction reporting processes, Travel Rule framework
FINTRAC registration submission
Submit MSB registration via FINTRAC's online portal; provide business details, VC services, compliance officer information
Registration confirmation and activation
FINTRAC confirms registration; compliance obligations commence immediately from registration date
What Canada MSB covers for virtual currency
Compliance and AML/CFT obligations (ongoing)
Fee schedule — Canada MSB Registration (FIL professional fees included)
| Service | Amount | Frequency | Notes |
|---|---|---|---|
| FIL professional fee (all-inclusive MSB registration) | |||
| End-to-end Canada MSB registration Scoping, entity advice, AML/CFT compliance programme preparation, KYC/CDD procedures, STR/LCTR reporting templates, Travel Rule framework, FINTRAC registration submission, compliance officer onboarding support, post-registration compliance calendar |
USD 36,000 | One-off | All-inclusive FIL professional fee for registration and initial compliance setup. Payable 100% on contract signing. |
| Entity incorporation (Canada) | |||
| Federal or provincial corporation incorporation Certificate of Incorporation, Articles, registered agent, registered office (Year 1) |
CAD 2,500 ~USD 1,850 |
One-off | Federal (CBCA) or provincial incorporation; federal recommended for national operations |
| Bank of Canada registration & corporate bank account opening | USD 2,500 | One-off | FIL banking introduction; Canadian bank accounts for VC businesses require careful preparation |
| Government fees (payable to FINTRAC/government) | |||
| FINTRAC MSB registration fee | No fee | One-off | FINTRAC MSB registration is free of charge |
| Annual corporate filings and registered office | CAD 4,500 ~USD 3,300 |
Annual | Annual return filings, registered office maintenance, good standing |
| MSB renewal with FINTRAC | No fee | Every 2 years | FINTRAC renewal is free; must be completed before registration expires |
| Mandatory ongoing costs (monthly) | |||
| Monthly Compliance Officer (mandatory) Ongoing AML/CFT compliance management, FINTRAC reporting, risk assessment updates, regulatory change monitoring, STR/LCTR oversight |
USD 3,500/month | Monthly | Mandatory; FINTRAC conducts periodic compliance audits |
| Private Desk / office (mandatory) Dedicated private desk in a shared or serviced office space in Canada — required for MSB compliance and regulatory correspondence |
~USD 400/month | Monthly | Approximate cost; actual rate depends on city and provider |
| Year 1 total (registration + incorporation + bank account) ~USD 41,800 | FIL professional fee USD 36,000 + Incorporation ~USD 3,300 + Bank/registration USD 2,500. No government licensing fee. Monthly Compliance Officer USD 3,500/month billed separately. | ||
End-to-end delivery across both jurisdictions.
Seychelles VASP — Regulatory
- Consultation and licence class selection
- Company incorporation (Seychelles entity)
- Registered office (Year 1)
- Business plan drafting (3-year model)
- AML/CFT policy and compliance manual
- Cybersecurity and IT security documentation
- FSA application submission and liaison
- Post-submission query management
Seychelles VASP — Operational
- Local Director provision
- Compliance Officer / MLRO provision
- Staff recruitment (headhunting)
- Office lease sourcing
- Bank account opening introduction
- Annual return filing
- Annual compliance calendar and reporting
- Travel Rule implementation guidance
Canada MSB — Full Service
- Entity advice and incorporation
- AML/CFT compliance programme
- KYC/CDD and EDD procedures
- STR and LCTR reporting templates
- Travel Rule framework (VC transfers)
- FINTRAC registration submission
- Compliance officer onboarding support
- Annual compliance review (optional)
Seychelles VASP vs Canada MSB — side-by-side.
| Parameter | Seychelles VASP | Canada MSB |
|---|---|---|
| Regulatory type | Full VASP licence (FSA, Seychelles) | Federal MSB registration (FINTRAC, Canada) |
| Governing law | VASP Act 2024 | PCMLTFA + FINTRAC Regulations |
| Activities covered | Exchange, custody/wallet, broker/dealer, advisory, transfer, token offerings, ATM | Virtual currency exchange and transfer only |
| Min. capital requirement | USD 25,000 to USD 100,000 depending on class | None |
| Govt application fee | USD 5,500 (all classes) | Free |
| Annual govt fee | USD 5,500 to USD 27,500 depending on class | Free (renewal every 2 years) |
| Estimated timeline | 6 to 8 months | 6 to 8 months |
| FATF status | Not on grey list (delisted Oct 2023) | FATF member in good standing (G7) |
| Local substance required | Yes — director, MLRO, office, staff, physical presence | No minimum substance requirements (compliance officer recommended) |
| Banking credibility | Good for African and Indian Ocean corridors | Excellent globally; G7 recognition by banks and institutions |
| Crypto scope | Broadest scope; all VA activities under one licence | Exchange and transfer only; securities excluded |
| Year 1 indicative cost | USD 57,000 to USD 62,000+FIL USD 48,000 + Secretary USD 4,500 + Bank USD 3,000 + Govt fees USD 5,500+. Excl. monthly operational costs. | ~USD 41,800FIL USD 36,000 + Incorporation + Bank. Monthly: CO USD 3,500 + Desk ~USD 400. |
Adjust your priorities. See which jurisdiction fits your business best.
Drag the segment boundaries on the pie chart to weight what matters most. The ranking table updates in real time, showing which jurisdiction best serves your stated priorities.
Start with Canada. Build toward Seychelles.
The Canada MSB registration is the fastest, lowest-cost, and highest-credibility first step for any virtual asset business. With no minimum capital, no government fee, and a 4 to 8 week timeline, it delivers immediate operational legitimacy and opens doors to institutional banking and partnerships in North America and beyond.
The Seychelles VASP licence should follow as the primary regulated entity for clients seeking the broadest virtual asset service scope — including exchange, custody, brokerage, and advisory — under a dedicated licensing framework. Seychelles provides the operational home; Canada provides the global credibility wrapper.
For businesses specifically targeting the GCC-Africa corridor or African markets, the Seychelles VASP licence should be prioritised, as it is better recognised in those corridors than a Canadian MSB. The two structures are complementary and most powerful together.
From proposal to licensed operation.
Scope confirmation
Confirm which VASP licence class(es) are required for Seychelles and whether to proceed with Canada MSB concurrently. Sign engagement letter and remit initial invoice.
KYC and entity setup
Provide KYC documentation for all directors, shareholders, and UBOs. FIL initiates Seychelles incorporation and Canada entity setup simultaneously.
Documentation and registration
FIL prepares full application packs for both jurisdictions. Canada MSB registration submitted; full process 6 to 8 months including entity setup, compliance programme, and FINTRAC processing. Seychelles application submitted once documentation is complete.
Seychelles licence issuance
FSA completes review and issues VASP licence. FIL supports post-licence operational setup including Travel Rule implementation, first compliance filings, and staff onboarding.