Overview
The Anjouan crypto license is a digital-asset-specific authorisation for VASPs (Virtual Asset Service Providers) operating in or from Anjouan. Activities in scope include cryptocurrency exchange operation, custody, wallet services, OTC trading, and token issuance. The framework is aligned with FATF guidance on VASP regulation and incorporates the travel rule for transfers above defined thresholds.
The license is separate from — and sometimes complementary to — the Anjouan gaming license. A crypto casino typically operates under the gaming license (which covers its crypto handling). An exchange or custodian operates under the crypto license. A business doing both needs both.
Who needs it
The Anjouan crypto license fits operators whose primary business is handling digital assets:
- Centralised exchanges — spot, margin, or derivatives trading.
- Custodians — holding digital assets on behalf of clients.
- Wallet providers — custodial wallet services.
- OTC desks — institutional and high-net-worth crypto brokerage.
- Token issuers — primary issuance of utility, security, or governance tokens.
- DeFi front-ends — particularly where they include KYC or custodial components.
- Stablecoin operators — issuers of Anjouan-domiciled stablecoins (a small but emerging category).
Pure technology providers — smart-contract developers, non-custodial wallet software — typically do not need this license. The test is whether you hold client assets or broker transactions between parties.
Activities covered
The license is scoped per authorised activity. Applicants specify which of the following they intend to conduct, and the license conditions are tailored accordingly:
- Fiat-to-crypto and crypto-to-fiat exchange.
- Crypto-to-crypto exchange.
- Custodial storage of client digital assets.
- Derivative and leveraged product operation (separate conditions apply).
- Token issuance and distribution.
- Staking and yield products (conditional — some forms are outside scope).
- OTC and institutional brokerage.
Adding activities post-issuance requires a variation application (€500–€1,500). Scope your authorisation to what you plan to launch in year one — expanding later is cheaper than rescoping during the initial application.
Cost
Year-one budget for an Anjouan crypto license runs €25,000–€50,000 depending on activity scope and whether custodial services are included.
| Line item | Low | Typical | High |
|---|---|---|---|
| Application fee | 12,000 | 15,000 | 18,000 |
| Annual license · year 1 | 10,000 | 12,000 | 15,000 |
| Company formation | 2,500 | 3,500 | 5,000 |
| AML / KYC drafting | 4,000 | 7,000 | 10,000 |
| On-chain analytics subscription | 6,000 | 10,000 | 18,000 |
| Compliance officer · 1 yr | 8,000 | 12,000 | 18,000 |
| Year-1 total | 42,500 | 59,500 | 84,000 |
The on-chain analytics subscription (Chainalysis, Elliptic, TRM Labs) is the biggest line item variance — institutional coverage runs €15,000+ per year but lighter-touch packages for low-volume operators are available.
Requirements
The crypto license application package includes:
- Anjouan-incorporated entity with digital-asset-specific business purpose clauses.
- Fit-and-proper review on all directors and UBOs ≥ 10%, with particular attention to prior regulatory history in other VASP jurisdictions.
- Technology and security documentation — wallet architecture (cold/hot separation), key management, multi-signature procedures, incident response.
- AML / KYC policy — FATF-aligned, with explicit on-chain provenance screening.
- Travel rule compliance plan — the technology and procedural plan for complying with inter-VASP information-sharing obligations.
- Client-asset segregation policy — custodial and non-custodial segregation.
- Capital adequacy — varies by activity. Pure exchange operation: €50,000 minimum. Custody: €150,000+ depending on assets under custody.
- Proof of insurance — crime and cyber coverage, where providing custodial services.
AML obligations
AML for a crypto license is substantially more operationally demanding than for a gaming license. Key requirements:
- On-chain analytics on every deposit at defined thresholds (typically $1,000+ equivalent). Sanctioned-wallet and mixer exposure are automatic holds.
- KYC at account opening for all customers, with enhanced due diligence for high-risk jurisdictions and PEPs.
- Source-of-wealth verification for high-value customers (typically $50,000+ equivalent cumulative deposits).
- Transaction monitoring for unusual activity patterns — rapid pass-through, layering, structuring.
- Suspicious transaction reporting to the Anjouan Financial Intelligence Unit.
- Annual AML audit by an independent reviewer.
Travel rule
The FATF travel rule — requiring VASPs to share originator and beneficiary information on transfers above $1,000 equivalent — is part of Anjouan's crypto licensing framework. Licensees must integrate with a travel-rule messaging protocol (Sumsub Travel Rule, TRP, or Notabene are the current standards — OpenVASP was deprecated in 2024) and maintain records of the exchanged information.
For deposits and withdrawals involving unhosted (self-custody) wallets, the operator must perform enhanced due diligence to verify control of the counterparty wallet. This is typically handled via a small-amount test transaction plus signature verification.
Gaming license vs crypto license — which do I need?
This is the most common question. The short decision tree:
- Your product is a casino that accepts crypto → gaming license. The crypto handling is covered.
- Your product is an exchange where users trade crypto → crypto license.
- Your product is a betting platform that denominates in crypto → gaming license.
- Your product is a wallet with no gambling → crypto license.
- Your product is both — an exchange with gambling products → both licenses.
If you're running a crypto casino specifically, see Anjouan gaming license for crypto casinos for the detailed interaction between crypto handling and gaming regulation.
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