Function before labelControl before assumptionRisk before scaleEvidence before conclusionPrivacy by designSecure change managementFunction before labelControl before assumptionRisk before scaleEvidence before conclusionPrivacy by designSecure change management

Independent decentralized VASP reference

Map decentralized control.
Design accountable services.

dVASP.com is a function-first field guide for understanding virtual-asset services across protocols, interfaces, entities, DAOs, wallets, and regulated operations.

10long-form implementation guides
6connected control workstreams
0token promotions or product endorsements
Colorful dVASP control map connecting users, entities, interfaces, keys, governance, data, rules, fees, and risk
Working definition: “dVASP” is this site’s shorthand for analyzing decentralized virtual-asset service models. It is not a universal legal category, registration, license, or conclusion.

The function-first method

One map. Six connected workstreams.

Move from product facts to control, risk, architecture, and jurisdiction—without assuming that “decentralized,” “software,” or “non-custodial” ends the analysis.

02

Control map

Trace keys, interfaces, governance, fees, and practical influence.

Open reference →
03

Risk model

Connect customer, geography, asset, product, and transaction risk.

Open reference →
04

Travel Rule

Design data, counterparty, message, exception, and privacy workflows.

Open reference →
05

Sanctions & security

Use accurate enforcement points, resilient data, and incident playbooks.

Open reference →
06

Regulatory map

Separate global standards from binding jurisdiction-specific law.

Open reference →

A repeatable review path

From architecture to accountable decisions.

Describe the service

Map user journeys, asset movement, counterparties, fees, and the service performed for others.

Identify people and control

Trace entities, administrators, keys, interfaces, governance, operational dependencies, and practical influence.

Apply risk and jurisdiction

Assess customers, assets, geographies, transactions, and the binding rules for each operating entity.

Design controls and evidence

Connect policy to real technical enforcement points, exception states, secure operations, and reproducible records.

The central question

Who can cause, prevent, shape, or profit from the service?

Control is layered. Smart contracts, front ends, governance, commercial arrangements, operations, and communications can have different owners and different consequences.

ProtocolUpgrade, pause, routing, parameters
InterfaceDefaults, access, lists, disclosures
GovernanceVotes, delegates, councils, vetoes
OperationsMonitoring, incidents, vendors, releases

Latest field notes

Practical guides for product and risk teams.

View all articles

Frequently asked questions

Clear boundaries before deeper analysis.

Is dVASP a formal legal category?

No. dVASP is a practical shorthand used by this site for examining decentralized virtual-asset service models. Legal classifications depend on the functions performed, the people and entities involved, control, location, and applicable law.

Does non-custodial always mean outside VASP scope?

No single architecture label decides the outcome. Non-custody is an important fact, but reviewers may also examine exchange, transfer, arrangement, interface, administrative, commercial, and governance functions.

What should a control map include?

At minimum: smart-contract permissions, interfaces, keys, governance, fees, entities, service providers, infrastructure, user relationships, incident powers, and evidence of how decisions are made.

Is this site legal or compliance advice?

No. It is an independent educational reference. Use qualified legal, compliance, security, and tax professionals for decisions about a particular product or jurisdiction.

Why combine compliance and security?

Controls depend on secure data, credentials, releases, vendors, logs, and incident response. A compliance rule cannot be effective if the system that enforces or records it is unreliable.