Identify each actual service
Virtual asset service provider, or VASP, describes a provider category. The product name does not decide which designated services the business provides.
Examine what the business does for customers, including exchange, safekeeping, transfers and relevant offer or sale services.
Source: AUSTRAC: Service description.
The service range is wider than exchange
AUSTRAC’s overview includes money-to-virtual-asset exchange, virtual-asset-to-virtual-asset exchange, arrangements for those exchanges and virtual asset safekeeping.
It also identifies ordering and beneficiary roles for transfers and relevant financial services connected with an offer or sale.
Each description has conditions. A wallet feature or token label alone does not establish the full legal classification.
Source: AUSTRAC: Service description.
- Exchange
Describe what is exchanged and who arranges it.
- Custody
Identify any safekeeping role.
- Transfer
Identify the transfer role and current transition conditions. The product name does not settle scope.
Map features to actual services
The feature’s actual function determines the service question. Exchange, safekeeping and transfer conditions must each be considered.
Separate evidence questions. An answer to one does not settle the others.
Invented example: a new wallet feature
In a fictional platform, a proposed feature would hold customer assets and accept instructions to transfer them. The team records the actual activities.
It examines the relevant safekeeping and transfer service conditions before release. A previous exchange registration does not answer every question about the new activity.
Keep technical evidence understandable
A practical record can connect wallet identifiers, customer instructions and transaction evidence. Explain what the technical record establishes and what remains uncertain.
A transaction identifier alone does not establish who controls a customer or why a transfer occurred. Apply the relevant CDD and record requirements.
Source: Federal Register of Legislation: 28, 30, 66A, 107 and 111.
Apply the correct transition
The deferral for new registrable virtual asset services ended on 1 July 2026. The item 50A exchange service had a different commencement treatment.
Later deferrals for IVTS reports and unverified self-hosted-wallet reports do not remove current travel-rule or SMR duties.
Use the current service and transition provisions. Do not assume every virtual-asset activity has the same reporting treatment.
Source: AUSTRAC: Deferred AML/CTF obligations; IVTS and unverified self-hosted wallet reports.