The right category
Category I for advice and intermediary services on crypto assets. Discretionary management of client crypto portfolios needs Category II, with its own competence and capital requirements.
FAIS Cat I · FIC Act Sch 1 item 22
Crypto Asset Service Provider Licensing
The FSCA licence and FIC Act framework that an exchange, custodian, broker or adviser needs to deal in crypto assets lawfully in South Africa.
Crypto assets are a financial product. Dealing in them needs a licence.
In October 2022 the FSCA declared crypto assets a financial product under the FAIS Act. From that date, anyone giving advice on or rendering intermediary services in relation to crypto assets (exchanges, brokers, custodians, arbitrage services, advisers and many token platforms) has needed an FSP licence with the crypto asset subcategory. Businesses that were already operating had a window to apply during 2023; new entrants must be licensed before they start. Two months later, in December 2022, crypto asset service providers were added to Schedule 1 of the Financial Intelligence Centre Act as accountable institutions, with the full set of FIC Act duties.
A CASP application therefore runs on two tracks at once. RCC prepares the FSCA application on the same two-phase process as any FSP licence application, and builds the FIC Act framework in parallel so that the business is compliant on both fronts on the day it opens.
The FSCA track
What the licence application must show
People who qualify
A Key Individual who meets the fit-and-proper requirements, representatives on the register, a section 17 compliance officer and an auditor. The competence requirements for the crypto asset subcategory follow Board Notice 194 of 2017.
Operational ability
Custody and key-management arrangements, cyber and information security, business continuity, complaints handling and record keeping, described in a business plan the FSCA can test.
Financial soundness
Balance-sheet evidence that the business meets the requirements for its category, plus the professional indemnity or fidelity cover the Board Notice prescribes.
Conduct framework
Disclosures that explain the risks of crypto assets in plain language, a conflict of interest management policy, advertising controls and a Treating Customers Fairly framework.
The FIC Act track
Accountable institution from day one
As a Schedule 1 item 22 accountable institution a CASP must register with the Financial Intelligence Centre on goAML, appoint the person responsible for compliance under section 42A, adopt and implement a Risk Management and Compliance Programme under section 42, verify every client and beneficial owner, screen against the targeted financial sanctions lists, monitor transactions, report suspicious and unusual transactions and cash above the threshold, keep records for five years and train staff. The Centre has also issued a directive implementing the "travel rule", which requires originator and beneficiary information to accompany crypto asset transfers between service providers.
RCC's FICA implementation team designs the RMCP around the way a crypto business actually onboards and transacts, including the wallet-screening, chain-analytics and travel-rule controls that a generic RMCP does not contain.
After licensing
Keeping a CASP licence in good standing
A licensed CASP files an annual compliance report, pays the FSCA levy, keeps its register of representatives current, meets CPD requirements for every Key Individual and representative, and is subject to FSCA conduct supervision and FIC inspections. RCC provides compliance monitoring and an outsourced compliance officer for CASPs that want the obligations run on a calendar rather than discovered at an inspection.
Common questions
Questions we are asked
Which crypto businesses need an FSP licence?+
Any person who gives advice or renders intermediary services in relation to crypto assets as defined in the FSCA's declaration: exchanges, brokers, custodians, over-the-counter desks, arbitrage and yield services, advisers and most token platforms that act between a client and a crypto asset. Mining and the development of software, on their own, are generally outside the definition. RCC confirms your position before you apply.
Can a foreign exchange serve South African clients without a licence?+
A business that renders financial services to clients in South Africa needs authorisation here, wherever it is incorporated. Several offshore platforms have been licensed through a South African entity. The structure is part of the scoping conversation.
How long does CASP licensing take?+
Two phases: preparation of the FSCA file and the FIC Act framework (weeks for a business with a qualifying Key Individual and documented controls; longer where people or policies still have to be put in place), then the FSCA's own review, which depends on its volumes and on how quickly queries are answered. A complete, consistent file at submission is the biggest factor in the second phase.
What does CASP licensing cost?+
The FSCA charges its own application fee and an annual levy, published in its fee schedule. RCC's fee covers the preparation and submission of the licence application, the drafting of the FIC Act framework and the handling of regulator queries, quoted as a fixed amount after scoping.
Do I also need to register with the FIC?+
Yes. Crypto asset service providers are accountable institutions under Schedule 1 of the FIC Act and must register on goAML, adopt an RMCP and comply with the Act regardless of the FSCA licence.
Related services
Services that go with this one
- FSP licence applicationsNew licences across all categories, crypto and insurance broker licensing, amendments and upgrades.Explore fsp licence applications
- FICA implementationRMCP drafting, AML and CFT measures, inspection readiness.Explore fica implementation
- Key individual servicesKey Individual placement, capacitation and training.Explore key individual services
- Compliance monitoringOngoing FAIS, FICA and NCA monitoring, plus outsourced compliance officer services.Explore compliance monitoring
See where your obligations actually stand.
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