Virtual Asset Service Providers Act, 2025
Also known as: Kenya Virtual Asset Service Providers Act, 2025
Overview
Key Details
Jurisdiction
KenyaRegulator
Capital Markets Authority / Central Bank of Kenya
Law Type
Act
Status
In ForceOfficial Law Number
Act No. 20 of 2025
Official Title
Virtual Asset Service Providers Act, 2025
Effective Date
November 4, 2025
Publication Date
October 15, 2025
Last Verified
August 26, 2026
Topics Covered
Who This Law Applies To
Key Requirements
Act No. 20 of 2025 applies to virtual-asset services offered in or from Kenya. It requires eligible companies to obtain a licence from the relevant authority, primarily the Capital Markets Authority or Central Bank of Kenya depending on activity. Licensees need a Kenyan office, suitable directors, capital, solvency, insurance, governance and technology controls. The Act protects customer assets, prohibits mixers and anonymity-enhancing services, imposes AML/CFT/CPF supervision and requires regulatory approval or no-objection for virtual-asset offerings.
Key Provisions
CMA/CBK regulatory roles; mandatory licensing; eligible company and local-office requirements; fit-and-proper management; capital, solvency and insurance; client-asset segregation; prohibited anonymity services; AML/CFT/CPF; offering approval; inspections, enforcement and penalties.
Licensing & Registration
No person may conduct or hold itself out as conducting covered virtual-asset services in or from Kenya without the appropriate licence from the relevant regulatory authority.
AML / CFT
VASPs are supervised for AML/CFT/CPF, with beneficial-owner and management vetting, onsite and offsite supervision, transaction monitoring, suspicious-reporting and sanctions obligations.
Custody & Safeguarding
Licensees must protect and segregate client virtual assets from proprietary assets and creditor claims and maintain appropriate safeguarding, records, controls and insurance.
Disclosure & Marketing
Marketing must not be fraudulent or misleading. Virtual-asset offerings require regulatory submission and written no-objection or approval, with consistency between approved information and promotions.
Market Integrity & Enforcement
The CMA, CBK or another designated authority may license, inspect, investigate, direct, restrict, suspend, revoke and impose administrative or criminal consequences.
Tax Treatment
The Act is regulatory and does not replace Kenya's tax laws; applicable income, corporate, VAT and digital-asset tax rules must be checked separately.
Related Laws
Decision No. E/35/2023 — VASP Registration and AML/CFT Instructions
Decision No. E/35/2023 on Virtual Asset Service Provider Registration, Cancellation of Registration and AML/CFT Instructions
Oman's FSA Decision No. E/35/2023 requires registration with the Oman Financial Services Authority (formerly Capital Market Authority) before carrying on covered virtual-asset activities in the Sultanate of Oman. It implements AML/CFT, governance and compliance requirements, and provides registration, cancellation and supervisory procedures. This is a VASP registration/AML regime and should be distinguished from any future full licensing framework.
BCB Resolutions No. 519, 520 and 521 of 2025 — Virtual Asset Regulatory Framework
Resoluções BCB nos. 519, 520 e 521, de 10 de novembro de 2025
Brazil's Central Bank (BCB) Resolutions No. 519, 520 and 521 of 10 November 2025 implement the virtual-asset regulatory framework under the supervision of the Central Bank. Resolution 519 establishes VASP authorisation procedures; Resolution 520 sets activity, governance, controls, security and conduct requirements; Resolution 521 integrates specified virtual-asset operations into Brazil's foreign-exchange and international-capital rules. Commencement is staged during 2026 — verify the effective date for each resolution separately.
Utility Token Offering Act, 2018 (Act No. 4/2018)
Utility Token Offering Act, 2018 (Act No. 4 of 2018)
Anguilla's Utility Token Offering Act 2018 (Act No. 4/2018) is one of the world's earliest purpose-built utility-token offering frameworks. It creates registration requirements for utility-token issuers, sets offering, disclosure and issuer-qualification conditions, and works with AML regulations and later amendments. Verify the most recent consolidation — a 2020 amendment may affect the effective/status fields.
SBS Resolution No. 02648-2024 — AML/CFT Rules for VASPs
Resolución SBS N.° 02648-2024 — Normas para la Gestión de Riesgos de LA/FT aplicable a PSAVs
Peru's SBS Resolution No. 02648-2024 applies AML/CFT risk-management and compliance duties to virtual asset service providers (PSAVs) supervised by UIF-Peru. It requires customer due diligence, recordkeeping and suspicious-transaction reporting. The resolution also contains a travel-rule chapter, but commencement of the travel rule has been deferred to 1 January 2029 through a later amendment — the travel rule is not currently effective.
Financial Market Digitalisation Act (Finanzmarktdigitalisierungsgesetz — FinmadiG)
Gesetz zur Digitalisierung des Finanzmarktes (Finanzmarktdigitalisierungsgesetz — FinmadiG)
Germany's Financial Market Digitalisation Act (FinmadiG) aligns German financial-market law with MiCA and DORA, establishes national supervisory powers and enforcement mechanisms for BaFin, and addresses the transition from existing German crypto-custody regulation. It applies to German financial entities, CASPs and other firms affected by MiCA/DORA national implementation.
Regulation (EU) 2024/1624 — Anti-Money Laundering Regulation (AMLR)
Regulation (EU) 2024/1624 of the European Parliament and of the Council on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing
Regulation (EU) 2024/1624 (AMLR) is a directly applicable EU regulation creating AML/CFT obligations for obliged entities, expressly including crypto-asset service providers (CASPs). It works with the AMLA Regulation, AMLD6 and the EU crypto travel rule. Note: the regulation is legally in force, but general application date is 10 July 2027 — it should not be described as currently applicable to CASPs.
