VASP and CASP Compliance Checker

What does your application do?

Select the primary activity — you can use embedded wallets with any of these

Exchange or trading platform

Users buy, sell, or swap digital assets on your platform

Payments or remittance app

Moving funds cross-border, payroll, or B2B settlements

DeFi protocol or aggregator

Lending, yield, DEX, or liquidity management product

Consumer or gaming app

NFTs, collectibles, rewards, in-app assets, or onchain gaming

Custody or asset management

Holding, safeguarding, or managing assets on behalf of users or institutions

Other or not sure

General crypto product or still evaluating the use case

How are wallets delivered in your application?

This is separate from your use case. An exchange can use embedded wallets; a DeFi app can require external wallets.

Embedded wallets

Your app creates wallets for users via passkeys, email, or social login.

External wallets

Users connect their own wallet. Your app does not provision or hold keys.

Both

Your app supports embedded wallets for new users and external wallet connection for existing crypto users.

Not decided yet

Still evaluating wallet infrastructure options.

Who controls the private keys?

This is the single most important factor in determining your regulatory classification

Your platform holds keys

You or your infrastructure provider manages private keys on behalf of users

Users hold their own keys

Users control key material, your platform only provides an interface

Share or split custody

Key shards split between user and provider (MPC, TSS, co-signing required)

Not sure, evaluating

Haven’t decided on a custody model yet

Where will you operate?

Select all regions where you plan to serve customers — multiple selections allowed

European Union

Subject to the MiCA CASP framework (Dec 2024)

United States

FinCEN and BSA, state money transmitter licenses, SEC and CFTC

United Kingdom

FCA registration, developing post-Brexit crypto framework

Asia Pacific

Singapore MAS, Hong Kong SFC, Japan FSA VASP regimes

Latin America

Varies by country; many FATF member states apply VASP rules

Africa

Varies by country; many FATF member states apply VASP rules

Global

Serving users worldwide or haven’t defined markets yet

How does your application handle money movement?

These factors shape which specific obligations apply to your platform

Does Your App Support Fiat On and Off Ramps?

Yes, users can deposit or withdraw fiat

Bank transfers, card top-ups, or cash-out to bank account

No, crypto only

No fiat conversion; users bring their own assets

Does Your App Transfer Assets Between Users?

Yes, peer transfers or payments

Users can send assets to other users or external wallets

No, no outbound transfers

Assets stay within your platform or are read-only

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Your compliance assessment

Based on your answers, here are the regulatory areas your application should investigate

Important disclaimer: This assessment is provided by Turnkey Global, Inc. for informational purposes only and does not constitute legal, regulatory, or compliance advice. The assessment is a general educational guide based on publicly available regulatory frameworks, including FATF Recommendation 15, the EU Markets in Crypto-Assets Regulation (EU 2023/1114), the Transfer of Funds Regulation (EU 2023/1113), and the Digital Operational Resilience Act (EU 2022/2554). Regulatory classification depends on your specific product, jurisdiction, business model, and the nature of your users and transactions. Classification standards vary across jurisdictions and are subject to change. This assessment reflects regulatory frameworks as of 25 March 2026. Verify current requirements before acting on these results. You should consult qualified legal counsel with expertise in financial services and crypto-asset regulation before making compliance decisions based on this output. Nothing in this tool creates an attorney-client or advisory relationship, and Turnkey assumes no liability for actions taken or not taken based on these results. Your use of this tool is subject to Turnkey\u2019s Terms of Service and Privacy Policy.