El Salvador has emerged as one of the world’s most forward-looking jurisdictions for digital assets. In 2023, the government enacted the Digital Assets Law and created the National Commission for Digital Assets (CNAD) — a specialized regulator overseeing tokenization, custody, and exchange services under a unified licensing regime.
The DASP Licence (Digital Asset Service Provider) is the cornerstone of this framework. It authorizes companies to legally operate within El Salvador’s blockchain ecosystem — from token issuance and exchange platforms to custody solutions and advisory services. This regime aligns with global best practices such as the EU’s MiCA Regulation and Mauritius’ VAITOS Act, while maintaining flexibility for innovative business models.
💡 Did you know? El Salvador was the first country in the world to adopt Bitcoin as legal tender and is now expanding its regulatory framework to support tokenization of real-world assets (RWA) — including real estate, bonds, and investment funds.
The DASP framework distinguishes between several categories of service providers:
- Issuers — entities creating and offering digital tokens or asset-backed securities.
- Exchanges — platforms enabling token trading and secondary market activities.
- Custodians — companies safeguarding private keys and client digital assets.
- Advisors & Brokers — intermediaries assisting with token sales and investment products.
Unlike many offshore jurisdictions, El Salvador provides clear legal recognition of digital assets and smart contracts. Licenced DASPs benefit from a predictable environment for banking, taxation, and cross-border operations — making the country a strategic hub for tokenization and compliant blockchain projects.
To apply for a DASP licence in El Salvador, companies must demonstrate both regulatory readiness and operational capability. The CNAD (National Commission for Digital Assets) evaluates applicants on governance, financial soundness, risk management, and technical infrastructure. Below is a summary of the main requirements every applicant should prepare before submitting the licence package.
🏢 Company Incorporation
Applicants must establish a local company in El Salvador or register a subsidiary. The entity should include in its corporate purpose the provision of digital asset services such as issuance, exchange, or custody.
🧾 Governance & Management
A DASP must appoint at least one Compliance Officer (MLRO), a local legal representative, and directors with verifiable experience in finance, compliance, or blockchain technology. Background checks and CVs are mandatory.
💰 Capital Requirements
Minimum paid-up capital depends on the activity type: Issuance or Exchange: USD 200,000 – 250,000 Advisory or Custody: USD 100,000 – 150,000 Capital proof and banking letters are required during submission.
📋 Compliance Documentation
Applicants must prepare a complete Compliance Manual, AML/CFT Policy, and Risk Management Framework. These documents must outline procedures for client onboarding, suspicious activity reporting, and ongoing due diligence.
🧠 Operational & Technical Setup
The CNAD requires a description of IT systems, cybersecurity measures, data protection standards, and business continuity plans. If blockchain infrastructure or custody providers are outsourced, service agreements must be attached.
🧾 Financial Reporting & Audit
A DASP applicant must submit audited financial statements (if operational) or proof of funds (for new entities). Annual audits and quarterly financial reports are part of ongoing obligations post-licensing.
⚖️ Tip: To speed up the DASP review process, prepare all documentation in bilingual format (English–Spanish) and ensure notarization of corporate and compliance materials before submission to the CNAD.
Meeting these prerequisites ensures that your company passes CNAD’s due diligence stage smoothly and demonstrates a professional approach to regulatory compliance — a key factor for obtaining approval and maintaining credibility with investors.
Below is the end-to-end process for obtaining a DASP licence in El Salvador. We recommend preparing bilingual (EN–ES) documents and securing local notary support to accelerate reviews by the CNAD.
Incorporation & Corporate Purpose
Incorporate a local entity or register a subsidiary. Include digital asset services (issuance/exchange/custody) in the corporate purpose. Prepare Articles, shareholder registry, and board resolutions.
Output: Certificate of IncorporationDirectors, MLRO & Local Rep
Appoint directors, a Compliance Officer (MLRO), and a local legal representative. Collect CVs, background checks, and fit & proper declarations for the CNAD.
Output: Appointments & DeclarationsPaid-in Capital & Banking Letters
Fund minimum paid-up capital per activity (e.g., issuance/exchange USD 200k–250k; custody/advisory USD 100k–150k). Obtain bank letters and proof of funds/source of funds.
Output: Capital ProofPolicies & Risk Framework
Prepare AML/CFT Policy, Compliance Manual, Risk Management Framework, onboarding flows (KYC/EDD), SAR escalation, record-keeping, and BCP/DRP.
Output: Compliance Pack (EN–ES)DASP Application to CNAD
Submit the licence dossier with all annexes: corporate docs, governance, capital, compliance pack, IT/cybersecurity, custody arrangements, and business plan with financial projections.
Output: DASP Application DossierRegulatory Review & Licence
Respond to CNAD queries/clarifications. Upon approval, receive licence and register in the official DASP registry. Proceed to open bank accounts, integrate KYC/custody, and go live.
Output: DASP Licence & Registry EntryOnce licensed, every DASP (Digital Asset Service Provider) in El Salvador must comply with continuous oversight by the CNAD. These obligations ensure transparency, AML integrity, and investor protection — aligning El Salvador with FATF standards and MiCA-level governance expectations.
🔍 Core Compliance Checklist
- Maintain an independent Compliance Officer (MLRO) and internal audit function.
- Update AML/CFT policies annually and document all client risk ratings.
- Perform periodic KYC refresh and sanctions screening (at least annually).
- Submit quarterly and annual reports to CNAD on transactions, capital, and compliance metrics.
- Ensure segregation of client assets and secure custody procedures.
- Conduct external financial and IT audits once per year.
Below is a summary of reporting obligations and their frequency. This table is formatted to be easily viewable on both desktop and mobile devices.
| Obligation | Frequency | Responsible Unit |
|---|---|---|
| AML/KYC Report — client risk summary and sanctions screening results. | Quarterly | Compliance Officer (MLRO) |
| Transaction & Capital Report — total volumes, liquidity ratios, and reserve proof. | Quarterly | Finance Department |
| Financial Statements — audited balance sheet, P&L, and asset segregation proof. | Annually | External Auditor / CFO |
| IT & Security Audit — system integrity, data protection, and custody resilience testing. | Annually | IT Security / External Consultant |
| Risk Management Review — evaluation of internal controls and risk scoring updates. | Semi-Annual | Risk Committee |
| Business Continuity Test — verification of backup, recovery, and data redundancy protocols. | Annually | Operations & IT |
Maintaining transparent reporting and robust documentation is critical not only for regulatory compliance but also for investor confidence. Regular audits, accurate filings, and continuous AML monitoring ensure your licence remains valid and trusted by partners worldwide.
A DASP licence in El Salvador provides a regulated pathway for tokenization, custody, and exchange operations — enhancing legal certainty, banking access, and investor trust. Below are the most impactful benefits for issuers and platforms.
🛡️Regulatory Recognition
Operate under a dedicated digital-assets law with a specialized regulator (CNAD). Smart contracts and tokenized RWAs receive explicit legal treatment.
Legal certainty🏦Banking & Custody Access
Improve access to crypto-friendly banking, payment rails, and institutional-grade custody via approved partners.
Operational readiness🌐Global Capital & Distribution
Launch tokenized offerings (real estate, funds, bonds) with cross-border investors under a clear compliance umbrella.
Tokenization-ready⚙️MiCA/VAITOS Alignment
Structure policies and disclosures to mirror best practices used in the EU and Mauritius — easier recognition by partners.
International standards📈Institutional Trust
Licensing boosts credibility with funds, family offices, and exchanges; improves due-diligence outcomes and listings.
DD friendly🔄Secondary Market Potential
Enable compliant secondary trading through partner ATS/bulletin boards, improving liquidity for investors.
Liquidity pathwayEl Salvador’s DASP framework sits within a global wave of digital-asset regulations, alongside the EU’s MiCA Regulation and Mauritius’ VAITOS Act. All three aim to establish legal certainty for tokenization, exchange, and custody — but differ in licensing scope, capital thresholds, and supervisory approach.
| Criteria | DASP (El Salvador) | MiCA (European Union) | VAITOS (Mauritius) |
|---|---|---|---|
| Regulator | CNAD — National Commission for Digital Assets. | National Competent Authorities (NCAs) under ESMA coordination. | Financial Services Commission (FSC) of Mauritius. |
| Legal Basis | Digital Assets Law (2023) — comprehensive digital asset regime. | Markets in Crypto-Assets Regulation (2023) — pan-EU harmonization framework. | Virtual Assets and Initial Token Offerings Services Act (2021). |
| Licence Categories | Issuance, Exchange, Custody, Advisory, and Broker Services. | CASP categories: custody, exchange, execution, advisory, and issuance. | Issuers, Custodians, Wallet Providers, and Marketplace Operators. |
| Capital Requirements | USD 100,000–250,000 depending on activity type. | EUR 50,000–150,000 depending on service category. | USD 35,000–200,000 depending on licence class. |
| Compliance Obligations | Local MLRO, AML/CFT program, quarterly reports, bilingual compliance documentation. | EU-standard AML/CFT, prudential safeguards, governance and cybersecurity audits. | FSC-approved Compliance Officer, annual AML audits, periodic FSC inspections. |
| Token Types Covered | All digital assets including asset-backed tokens, RWAs, and utility tokens. | Utility tokens, e-money tokens, and asset-referenced tokens (excludes securities). | Virtual assets, tokenized securities, NFTs, and hybrid products. |
| Supervision Intensity | Medium — CNAD review and quarterly filings. | High — ESMA oversight, cross-border compliance, public registry. | Medium — FSC monitoring and audit-based reporting. |
| Target Audience | Startups, tokenization projects, and exchanges seeking early regulatory adoption. | EU-based financial institutions and large-scale CASPs. | Tokenization platforms targeting African and Asian investor networks. |
While all three regimes share a similar regulatory intent, they differ substantially in flexibility and speed. El Salvador’s DASP licence stands out for its balance between regulatory recognition and operational efficiency. The CNAD offers a streamlined process for projects combining token issuance, custody, and exchange services — something that under MiCA often requires multiple licences and higher compliance costs.
The MiCA Regulation, meanwhile, establishes the most rigorous pan-European framework. It ensures investor protection and prudential safeguards but may slow down innovation for smaller projects due to capital and reporting demands. MiCA is best suited for large-scale CASPs and institutional players seeking access to all EU markets through a single licence passport.
The VAITOS Act in Mauritius bridges both extremes — offering moderate supervision and clear tax advantages. It’s a favored option for regional tokenization and DeFi projects that prioritize cross-border issuance flexibility and integration with fund structures or family offices.
In summary, El Salvador’s DASP framework is emerging as an attractive midpoint between innovation and regulation. Its licensing process is transparent, cost-effective, and directly aligned with global best practices — making it ideal for projects seeking to tokenize real estate, private credit, or investment funds under a single, recognized legal umbrella.
Applying for a DASP licence in El Salvador is a strategic decision that can position your project within a globally recognized legal environment. However, success depends on the quality of documentation, regulatory understanding, and communication with the CNAD. A well-structured submission not only accelerates approval but also builds long-term credibility with investors, banks, and partners.
Working with legal advisors who understand both blockchain technology and cross-jurisdictional compliance is essential. Experienced counsel can help you design the proper structure, coordinate with local notaries, and prepare bilingual (EN–ES) compliance documents that fully satisfy CNAD requirements. This is particularly important for tokenization projects that plan to issue or list assets internationally.
💡 Tip: Combine your DASP application with corporate setup, AML policy drafting, and technical advisory to streamline the entire process. Integrated packages save both time and cost, ensuring your licence dossier meets every CNAD standard from day one.
At GlobalTokenize Consulting, we collaborate directly with licensed legal partners in El Salvador, including local notaries and compliance experts. Our team assists in drafting operational policies, preparing AML and governance manuals, and representing clients before the CNAD. Whether you plan to tokenize real estate, funds, or securities, we provide an end-to-end legal framework adapted to your business model.
Ready to start your DASP journey?
Our specialists can help you establish a licensed presence in El Salvador, obtain a DASP licence, and build a compliant tokenization infrastructure — step by step.
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With the right structure and regulatory support, your company can become part of El Salvador’s fast-growing blockchain economy — combining innovation, legal protection, and investor trust under one unified licence.
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