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Financial Institutions

Expert Digital Asset Advisory Under Regulatory Authority

The Class I Virtual Asset Advisory Services licence authorises the provision of investment advice on virtual assets, covering portfolio composition, investment strategy, and digital asset allocation for sophisticated clients.

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Overview

What is a Class I Virtual Asset Advisory Services Licence?

As institutional and high-net-worth interest in digital assets has grown, so has demand for regulated, qualified advisory services. The Class I licence permits the holder to advise clients on virtual asset investments, recommending specific assets, portfolio strategies, and risk management approaches, without the trading permissions of the Class M licence.

It is ideally suited to boutique digital asset advisory firms, family office service providers expanding into digital assets, and traditional investment advisers seeking to offer digital asset guidance within a regulated framework. The FSC applies suitability assessment, disclosure, and conduct of business requirements to Class I licensees, ensuring that digital asset advice is provided responsibly to appropriately qualified clients.

Aurevya guides Class I applicants from advisory model design through FSC application, suitability framework development, client agreement preparation, and operational launch, with practical insight into both the regulatory requirements and the commercial realities of digital asset advisory practice.

VAITO Act
2021, FSC Licensed
Regulated under Mauritius's purpose-built virtual asset legislation, providing credible regulatory standing for investment advisers operating in the digital asset space.
Advisory
Only, No Trading
A precisely scoped advisory licence, authorising investment recommendations on virtual assets without trading or execution authority, reducing the regulatory burden relative to broker-dealer licences.
HNW &
Institutional Clients
Designed for advisory relationships with sophisticated clients, family offices, institutional investors, and qualified individuals seeking regulated digital asset investment guidance.

Scope of Authority

Key Features

Investment Advisory
Authorised to provide investment advice on virtual assets, recommending specific virtual assets, allocation strategies, and portfolio compositions to clients, under the FSC's conduct of business framework for virtual asset advisory services.
Portfolio Strategy
The Class I licence covers advice on portfolio-level digital asset strategies, including allocation between different virtual asset categories, rebalancing recommendations, and the integration of digital assets within broader investment portfolios.
Digital Asset Allocation
Advising on the appropriate allocation of client capital to digital assets, including the proportion of portfolio assets to allocate, the selection of specific virtual assets, and the risk management approach for digital asset exposures.
Risk Advisory
Providing clients with analysis and advice on the risk profile of virtual asset investments, volatility, liquidity, counterparty risk, regulatory risk, and technological risk, ensuring clients receive the balanced perspective required for informed decision-making.
Suitability Framework
The FSC requires Class I advisers to assess client suitability before providing recommendations, considering financial position, risk tolerance, investment objectives, and digital asset knowledge, ensuring that advice is appropriate for each client's individual circumstances.
FSC Regulated
Full VAITO Act regulatory standing, including ongoing FSC oversight, AML/CFT compliance, and conduct of business supervision, providing institutional clients and sophisticated investors with confidence in the regulatory standing of their digital asset adviser.

Process

How It Works

01
Advisory Model Design
We work with the applicant to define the advisory model, client segments, virtual asset categories to be advised upon, advisory methodology, fee structure, and the scope of the advisory relationship, confirming the Class I licence as the appropriate vehicle and scoping the application requirements.
02
Corporate Structure
Establishment of the Mauritius corporate structure, typically a Global Business Company (GBC), with appropriate governance, ownership structure, and the key personnel required for the FSC application, including the qualified digital asset adviser.
03
FSC Application
Preparation and submission of the complete VAITO Act Class I application, business plan, advisory model description, suitability framework, key personnel fit-and-proper submissions, financial projections, and AML/CFT programme, ensuring a complete and professionally presented application.
04
Suitability Framework
Design of the suitability assessment procedures required for Class I advisory, client financial profile assessment, risk tolerance evaluation, digital asset knowledge assessment, and the documentation standards required to demonstrate that advice is appropriate for each client.
05
Client Agreement Design
Preparation of the client-facing documentation required for regulatory compliance, advisory agreements, disclosure documents, risk warnings, and fee disclosure statements, ensuring the commercial relationship with clients is properly documented and FSC-compliant from inception.
06
Licence Grant
Active management of the FSC review process through to licence grant, followed by operational readiness coordination, ensuring the Class I adviser is prepared to onboard clients and deliver compliant advisory services from the moment the licence is granted.

Practical Considerations

Requirements & Timeline

Regulatory Requirements

  • Minimum capital, fully paid up and maintained at all times
  • Qualified digital asset adviser with relevant expertise approved by the FSC
  • Suitability assessment procedures for all advisory relationships
  • Client disclosure documents, advisory agreement, risk warnings, fee disclosure
  • AML/CFT compliance programme
  • Fit-and-proper assessment for all key personnel and beneficial owners
  • Ongoing FSC reporting including financial returns and compliance disclosures

Indicative Timeline

  • Corporate Setup: 2–3 weeks from completion of KYC and structure documentation
  • Application Preparation: 4–7 weeks, the suitability framework and advisory documentation are typically the primary preparation elements
  • FSC Review: 10–16 weeks from submission, the adviser qualifications and suitability framework are core elements of the FSC review
  • Operational Launch: 2–4 weeks post-licence grant for client onboarding and operational setup

Common Questions

Frequently Asked Questions

No. The Class I licence is limited to investment advisory services, the holder may recommend virtual asset investments to clients but may not execute trades or hold client assets on their behalf. An entity wishing to both advise on and trade virtual assets would require the Class M (Virtual Asset Broker-Dealer) licence. Many Class I advisers work in conjunction with Class M broker-dealers, providing the advisory relationship while directing execution to a separate licensed trading entity. Aurevya advises on structuring advisory and execution arrangements appropriately within the VAITO Act framework.
The FSC requires Class I licensees to demonstrate appropriate digital asset expertise through the qualifications and experience of their key advisory personnel. While there is no single prescribed qualification, the FSC will assess whether the proposed adviser possesses the combination of financial advisory experience, digital asset knowledge, and professional background appropriate for the scope of advisory services proposed. Traditional investment advisory qualifications combined with demonstrated digital asset knowledge are typically well-received. Aurevya advises on presenting adviser credentials in the most favourable light for the FSC's assessment.
Class I advisers are required to assess the suitability of virtual asset investment recommendations for each client before providing advice. This requires collection and assessment of information on the client's financial situation (assets, liabilities, income), investment objectives, risk tolerance, and knowledge and experience of virtual asset investments. The adviser must document the basis on which recommendations are assessed as suitable for each client and must update the suitability assessment when material changes in the client's circumstances occur. Aurevya designs suitability frameworks that are both FSC-compliant and practically workable for advisory operations.
The Class I licence is limited to investment advisory services, providing recommendations and guidance to clients on virtual asset investments without executing trades or holding assets. The Class M licence is a full broker-dealer authorisation, permitting the holder to trade, exchange, and hold virtual assets on behalf of clients. The Class M carries significantly higher capital requirements, technology review obligations, and operational compliance burdens reflecting its trading and custody activities. The Class I is the appropriate licence for pure advisory practices; the Class M is required where the adviser also wishes to execute transactions or hold client assets.
Class I licensees are subject to ongoing FSC reporting obligations, including annual financial returns, AML/CFT compliance reports, and any material change notifications required by the VAITO Act. The adviser must also maintain records of all advisory relationships, suitability assessments, and advice provided, which are subject to FSC inspection. Aurevya's compliance support services assist Class I licensees in maintaining their ongoing reporting obligations efficiently, ensuring continuous regulatory compliance without disrupting advisory operations.

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