Philippines BSP VASP Guidelines

Philippines BSP VASP Guidelines refers to Bangko Sentral ng Pilipinas Circular No. 1108, Series of 2021, titled Guidelines for Virtual Asset Service Providers. The Circular established the BSP’s framework for virtual asset service providers (VASPs) as money service businesses subject to BSP authority, licensing, examination, AML/CFT, consumer-protection, cybersecurity, custody, reporting, and governance requirements. It was issued after Monetary Board approval on Jan. 21, 2021 and became effective on Feb. 16, 2021. As of June 5, 2026, the regime remains in force, although BSP Circular No. 1206 later deleted and superseded the former MORNBFI Sections 901-N and 902-N and incorporated the rules into the consolidated MORNBFI-M M-Regulations.

Scope of BSP Circular No. 1108

Circular No. 1108 applies to VASPs that offer services or engage in VASP activities in the Philippines. It uses the Financial Action Task Force-based virtual asset and VASP terminology, replacing the earlier virtual currency exchange framing. The Circular covers exchange between virtual assets and fiat currencies, exchange between one or more forms of virtual assets, transfer of virtual assets, and safekeeping or administration of virtual assets or instruments enabling control over virtual assets. It excludes, among other matters, participation in or provision of financial services related to an issuer’s offer or sale of a virtual asset, which the Circular says falls under the Securities and Exchange Commission.

Licensing, Capital, and BSP Supervision

VASPs must secure a Certificate of Authority as a money service business from the BSP. The framework requires assessment of beneficial owners and ties authorization to fit-and-proper standards, registration procedures, and ongoing compliance with BSP expectations for outsourcing, liquidity risk, operational risk, IT risk, business continuity, internal controls, AML, consumer protection, and corporate governance. Circular No. 1108 set minimum paid-in capital of PHP 50 million for VASPs with safekeeping or custody services and PHP 10 million for VASPs without custody activities; those capital thresholds are retained in the consolidated M-Regulations.

AML/CFT, Travel Rule, and Transaction Controls

The VASP framework integrates AML/CFT controls into BSP supervision. VASPs must conduct customer due diligence for customers transacting above the relevant threshold, which Circular No. 1108 set at PHP 5,000 for occasional transactions. Virtual asset transfers are treated as cross-border wire transfers and trigger originator and beneficiary information requirements at PHP 50,000 or above. For large-value pay-outs above PHP 500,000, the rules call for enhanced due diligence and payment through check, direct credit to deposit accounts, or account-to-account transfer using electronic fund transfer facilities.

Custody, Cybersecurity, and Consumer Protection

The Circular places particular emphasis on wallet security and technology controls. VASPs are expected to maintain wallet-security programs for private-key handling, cybersecurity, outsourcing, internal controls, audit, and operational resilience. Consumer-protection provisions address clear communication of fees, risks, contractual terms, complaint mechanisms, and ownership or custody risks. The current M-Regulations also contain reserve, segregation, and liquidity-related expectations for custodial VASPs that hold virtual assets on behalf of customers.

Current Status and Jurisdictional Impact

The BSP has also modified market-entry policy. Memorandum No. M-2022-035 closed the regular application window for new VASP licences for three years beginning Sept. 1, 2022. Memorandum No. M-2025-031 continued the moratorium from Sept. 1, 2025, subject to reassessment. Separately, Memorandum No. M-2026-003 reminded BSP-supervised financial institutions to deal only with authorized or licensed VASPs, SEC-authorized crypto asset service providers, or appropriately licensed foreign counterparties, and stated that direct retail access in the Philippines to offshore VASPs is not allowed unless the provider is registered with the BSP or SEC.

This is a Philippines national regulator-rule profile. It does not cover every SEC token-offering rule, tax treatment, securities classification issue, or consumer claim pathway. Its main relevance is to exchanges, custodians, transfer providers, wallet businesses, fiat-to-virtual-asset businesses, banks dealing with VASPs, and compliance teams tracking Philippine virtual-asset regulatory obligations.