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Financial Services

The Premier Virtual Asset Trading Licence in Mauritius

The Class M Virtual Asset Broker-Dealer licence is the most commercially significant virtual asset licence in Mauritius, authorising the exchange of virtual assets and fiat currency on behalf of clients, as a broker-dealer. Operating a virtual asset exchange or trading venue for third parties is licensed separately, under Class S; custody of client virtual assets is licensed separately, under Class R.

Overview

What is a Class M Virtual Asset Broker-Dealer?

Mauritius's Virtual Asset and Initial Token Offering Services Act 2021 (VAITOS) establishes a comprehensive licensing framework for virtual asset service providers. The Class M licence is the most sought-after category, authorising the exchange of virtual assets and fiat currency on behalf of clients, as a broker-dealer. Operating a virtual asset exchange or trading venue for third parties is licensed separately, under Class S; custody of client virtual assets is licensed separately, under Class R.

It is the natural licence for entities building regulated cryptocurrency exchanges, OTC digital asset desks, or virtual asset trading platforms targeting professional and institutional clients. Mauritius's Class M licence has attracted significant international interest as a credible alternative to less regulated jurisdictions, combining genuine regulatory substance with commercial flexibility.

Aurevya advises Class M applicants from initial business model assessment through FSC application, technology review, AML/CFT programme design, and operational setup, with a practical understanding of both the regulatory requirements and the commercial realities of building a virtual asset trading operation.

VAITOS
2021, FSC Licensed
Regulated under Mauritius's purpose-built virtual asset legislation, providing a credible, internationally recognised regulatory framework for virtual asset service providers.
MUR 2,000,000
Minimum Own-Funds Requirement
Minimum own-funds requirement of MUR 2,000,000 (or a higher amount, as determined by the FSC, reflecting the nature, scale and complexity of the licensee's activities), reflecting the commercial significance and risk profile of broker-dealer operations in virtual asset markets — we confirm the current figure with the FSC as part of every engagement.
4–6
Months, Application Timeline
From initial engagement to licence grant, subject to FSC processing, technology review, and the completeness of the application package submitted.

Scope of Authority

Key Features

Virtual Asset Trading
Authorised to buy and sell virtual assets, including cryptocurrencies and other digital assets, on behalf of clients and on a proprietary basis, across both retail and institutional client categories subject to FSC conditions.
Dealing & Exchange of Assets
The Class M licence authorises exchanging virtual assets for fiat currency or other virtual assets, and dealing as principal or agent, on behalf of clients, distinct from operating a trading venue (Class S) or holding client assets in custody (Class R).
OTC Desk Authority
The broker-dealer structure accommodates OTC (over-the-counter) trading desks, providing bespoke virtual asset execution services to institutional and professional counterparties outside the order book of a formal exchange.
Client Brokerage
Authorised to act as agent or principal in virtual asset transactions for clients, receiving client orders, executing trades, and managing the client relationship within the FSC's conduct of business framework for virtual asset service providers.
FSC Oversight
Full VAITOS regulatory oversight, including technology platform review, AML/CFT supervision, and ongoing reporting, providing institutional counterparties and clients with confidence in the regulatory standing of the Mauritius virtual asset broker-dealer.

Process

How It Works

01
Business Model Assessment
We assess the proposed virtual asset business, target virtual assets, client segments, trading model (exchange, OTC, or both), custody arrangements, and geographic markets, confirming the Class M licence as the appropriate regulatory vehicle and scoping the application requirements.
02
Technology Review
The FSC scrutinises the technology platform of Class M applicants, trading engine, wallet infrastructure, security architecture, and cybersecurity controls. We prepare the technology documentation for FSC review and identify any platform enhancements required before application.
03
FSC Pre-Application
Where appropriate, we facilitate a pre-application engagement with the FSC, presenting the virtual asset business model and obtaining regulatory guidance before the formal application is submitted, reducing the risk of material queries during the review period.
04
Formal Application
Preparation and submission of the complete VAITOS Class M application, business plan, technology overview, AML/CFT programme, KYC documentation, key personnel fit-and-proper submissions, and financial projections.
05
IT & Compliance Review
Active management of the FSC review, including technology assessment queries, AML/CFT programme review, and compliance framework evaluation. We maintain regular engagement with the FSC throughout the assessment period to ensure timely progress.
06
Licence Grant
Upon licence grant, we coordinate operational readiness, final platform configuration, client onboarding procedures, and compliance programme activation, ensuring the entity is ready to begin regulated virtual asset trading operations from day one.

Practical Considerations

Requirements & Timeline

Regulatory Requirements

  • MUR 2,000,000 minimum own-funds requirement (or a higher amount, as determined by the FSC, reflecting the nature, scale and complexity of the licensee's activities), fully paid up — we confirm the current figure with the FSC as part of every engagement
  • At least three directors, of whom at least 30% must be independent and at least one must be ordinarily resident in Mauritius
  • AML/CFT programme aligned with FATF virtual asset guidance
  • Qualified Compliance Officer approved by the FSC
  • Technology platform review by the FSC, trading engine, wallet security, cybersecurity
  • Secure custody arrangement for client virtual asset holdings
  • Detailed business plan including virtual asset categories to be traded
  • Fit-and-proper assessment for all key personnel and beneficial owners
  • Ongoing FSC reporting including financial returns and AML/CFT disclosures

Indicative Timeline

  • Corporate Setup: 2–3 weeks from completion of KYC and structure documentation
  • Application Preparation: 4–8 weeks, technology documentation and AML/CFT programme are typically the most time-intensive elements
  • FSC Review: 6–8 weeks from submission for formal review by the FSC Virtual Asset Supervision team
  • Operational Launch: 3–6 weeks post-licence grant for final platform configuration and client onboarding setup

Common Questions

Frequently Asked Questions

VAITOS defines virtual assets broadly, covering cryptocurrencies, digital tokens, and other digital representations of value that can be digitally traded or transferred. The specific virtual assets that a Class M licensee intends to deal in must be described in the business plan submitted to the FSC. The FSC may require additional information on the technical characteristics and risk profile of certain virtual assets, particularly those outside the mainstream cryptocurrency categories. Aurevya advises on how to scope and present the proposed virtual asset universe in a manner that is commercially workable and acceptable to the FSC.
The FSC requires a minimum own-funds requirement of MUR 2,000,000 (or a higher amount, as determined by the FSC, reflecting the nature, scale and complexity of the licensee's activities) for a Class M Virtual Asset Broker-Dealer licence. This must be fully paid up and maintained at all times. The FSC also applies ongoing capital adequacy requirements that reflect the risk profile of the virtual asset broker-dealer's operations. Aurevya's compliance team assists with capital planning and ongoing capital adequacy monitoring to ensure the entity remains compliant throughout its operating life.
The Class M licence authorises the holder to act as broker-dealer, buying and selling virtual assets on behalf of clients or as principal, and operating an exchange where the licensee is a counterparty. The Class S licence authorises the operation of a marketplace or peer-to-peer trading platform where buyers and sellers interact directly with each other, rather than through the licensee as principal or agent. The Class M model is more analogous to a traditional broker-dealer or exchange operator; the Class S model is more analogous to a decentralised or peer-to-peer marketplace operator.
Virtual asset service providers under VAITOS are subject to comprehensive AML/CFT requirements aligned with FATF's guidance on virtual assets. This includes robust KYC procedures for all clients, transaction monitoring calibrated to virtual asset risks, Travel Rule compliance for virtual asset transfers, suspicious activity reporting, and regular AML/CFT programme review. The FSC assesses the AML/CFT programme as a core element of the Class M licence application. Aurevya designs VASP-specific AML/CFT programmes that meet both FSC requirements and international best practice for virtual asset businesses.
The Class M licence does not inherently prohibit retail client services, but the FSC applies conduct of business requirements that must be met when serving retail clients, including disclosure of risks, client categorisation, and appropriate product access controls. Many Class M licensees initially focus on professional and institutional clients, where the regulatory requirements are more proportionate and the commercial relationships are more straightforward. The decision to extend services to retail clients should be addressed explicitly in the business plan submitted to the FSC as part of the licence application.

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We guide virtual asset broker-dealers through Class M licensing and the trading infrastructure it requires.

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