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Financial Institutions

The Entry-Level Virtual Asset Licence

The Class O Virtual Asset Wallet Services licence authorises the safekeeping and administration of virtual assets on behalf of clients, the foundational licence for custodial wallet service providers seeking regulatory standing in Mauritius.

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Overview

What is a Class O Virtual Asset Wallet Services Licence?

The Class O licence under the VAITO Act 2021 is the most targeted virtual asset licence, focusing on the provision of custodial wallet services, including the safekeeping of cryptographic keys and the management of virtual asset balances on behalf of clients. It does not permit trading, exchange, or advisory activities.

The Class O provides a proportionate regulatory framework for entities whose core business is wallet infrastructure, exchange platforms, payment providers, and digital banks that hold virtual assets on behalf of users. The FSC applies AML/CFT and operational security requirements proportionate to the custody risks inherent in virtual asset holding.

Aurevya guides Class O applicants from initial scope assessment through FSC application, security architecture documentation, AML/CFT programme design, and operational launch, ensuring that wallet service providers obtain their licence efficiently and maintain compliance from the outset.

VAITO Act
2021, FSC Licensed
Regulated under Mauritius's purpose-built virtual asset legislation, providing a credible, internationally recognised regulatory framework for custodial wallet service providers.
Defined
Custody Scope
A precisely scoped licence covering custodial wallet services only, enabling targeted authorisation for entities whose business is wallet infrastructure rather than trading or advisory.
Lowest
Capital Threshold
The Class O carries the lowest minimum capital requirement among the VAITO Act licence categories, reflecting the narrower risk profile of custody-only operations relative to trading licences.

Scope of Authority

Key Features

Custodial Wallet Services
Authorised to provide custodial wallet services, holding virtual assets on behalf of clients and maintaining control of cryptographic keys used to access those assets, under direct FSC oversight and in compliance with the VAITO Act 2021.
Cryptographic Key Management
The Class O licence specifically covers the safekeeping of cryptographic keys, the private keys that control access to virtual asset holdings, requiring robust security infrastructure, access controls, and key recovery procedures.
Client Virtual Asset Holding
Authorised to maintain virtual asset balances on behalf of clients, including processing deposits and withdrawals, with full client asset segregation requirements to ensure that client virtual assets are protected from the licensee's own assets.
Proportionate Framework
Regulatory requirements calibrated to the custody-only scope of the Class O licence, AML/CFT, technology security, and operational governance obligations that are proportionate to wallet service risks rather than the broader obligations applied to trading entities.
Fintech-Compatible
Ideally suited to digital banks, payment platforms, and exchange operators that require a standalone custody authorisation to hold virtual assets on behalf of users within a regulated, FSC-overseen structure, without requiring a full broker-dealer licence.
FSC Regulated
Full VAITO Act regulatory standing, including FSC technology platform review, AML/CFT supervision, and ongoing reporting obligations, providing clients and institutional counterparties with confidence in the regulatory standing of the Class O wallet service provider.

Process

How It Works

01
Business Model Review
We assess the proposed wallet service business, the scope of custodial services, the virtual assets to be held, client segments, and technology architecture, confirming the Class O licence as the appropriate regulatory vehicle and scoping the application requirements.
02
Technology Security Assessment
The FSC scrutinises the technology infrastructure of wallet service providers, key storage mechanisms, access controls, cybersecurity architecture, and incident response procedures. We prepare the technology documentation for FSC review and identify any platform enhancements required before application.
03
FSC Application
Preparation and submission of the complete VAITO Act Class O application, business plan, technology overview, key personnel fit-and-proper submissions, financial projections, and corporate structure documentation, ensuring a complete and well-presented application package.
04
AML/CFT Framework
Design and implementation of an AML/CFT programme tailored to custodial wallet service risks, including client due diligence procedures, transaction monitoring for virtual asset flows, suspicious activity reporting, and compliance officer appointment.
05
Licence Grant
Active management of the FSC review process, including responses to technology assessment queries and compliance programme review, maintaining engagement with the FSC to ensure timely progress through to licence grant.
06
Operations Launch
Upon licence grant, we coordinate operational readiness, final security configuration, client onboarding procedures, and compliance programme activation, ensuring the entity is ready to commence regulated wallet service operations from day one.

Practical Considerations

Requirements & Timeline

Regulatory Requirements

  • Minimum capital (lower than trading licences), fully paid up and maintained at all times
  • AML/CFT programme aligned with FATF virtual asset guidance
  • Secure technology infrastructure, key storage, access controls, cybersecurity
  • Client asset segregation, virtual assets held separately from licensee's own assets
  • Qualified Compliance Officer approved by the FSC
  • Detailed business plan describing the scope of wallet services and virtual assets to be held
  • Fit-and-proper assessment for all key personnel and beneficial owners

Indicative Timeline

  • Corporate Setup: 2–3 weeks from completion of KYC and structure documentation
  • Application Preparation: 3–6 weeks, technology security documentation is typically the most time-intensive element
  • FSC Review: 10–16 weeks from submission, the technology assessment is a core element of the FSC review process
  • Operational Launch: 2–4 weeks post-licence grant for final configuration and client onboarding setup

Common Questions

Frequently Asked Questions

The Class O licence authorises the provision of custodial wallet services, specifically the safekeeping of cryptographic keys and the management of virtual asset balances on behalf of clients. This includes receiving and storing virtual assets on behalf of clients, controlling the private keys that govern those assets, and processing transfers at client instruction. The Class O does not permit the holder to trade, exchange, or provide investment advice on virtual assets. It is a custody-only licence, providing a precisely scoped regulatory standing for wallet service providers.
No. The Class O licence is limited to custodial wallet services. An entity wishing to both hold virtual assets on behalf of clients and trade or exchange virtual assets would require a Class M (Virtual Asset Broker-Dealer) licence, which encompasses the broader suite of virtual asset service activities. Many entities begin with a Class O licence for their custody operations and subsequently seek Class M authorisation as their business model expands. Aurevya advises on the optimal licence structuring for multi-activity virtual asset businesses.
The FSC applies technology security requirements to Class O applicants that are proportionate to the custody risks of wallet services. Key areas assessed include: the key management architecture (hot vs. cold storage, multi-signature arrangements), access controls and authorisation procedures for key usage, cybersecurity measures against external attack, incident response and key recovery procedures, and business continuity planning for wallet infrastructure. The FSC reviews the technology platform as part of the licence application, and the Class O holder must maintain these standards on an ongoing basis, subject to periodic FSC review.
Both the Class O and Class R are custody-focused licences, but they serve different market segments and carry different regulatory standards. The Class O is designed for retail-oriented wallet service providers, digital banks, payment apps, and fintech platforms holding virtual assets on behalf of general users. The Class R is the institutional-grade custodian licence, designed for entities providing professional safekeeping services to funds, family offices, and sophisticated investors, requiring higher capital, multi-signature security, cold storage infrastructure, and insurance against loss. The Class R carries more demanding operational requirements reflecting the institutional mandates of its clients.
From initial engagement, Aurevya typically requires 3–6 weeks to prepare a complete Class O application, the primary time driver being the technology security documentation required for the FSC's platform review. Following submission, the FSC's review process typically takes 10–16 weeks, subject to any additional information requests. Total timeline from engagement to licence grant is typically 4–6 months for well-prepared applicants. Corporate setup, AML/CFT programme design, and technology documentation can proceed in parallel to optimise the overall timeline.

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