GG-ALD#
The Bailiwick of Guernsey (Guernsey, Alderney and Sark treated as one regulatory unit for financial-services licensing) operates a Virtual Asset Service Provider (VASP) licensing regime under the Lending, Credit and Finance (Bailiwick of Guernsey) Law, which entered into force in July 2023 and is administered by the Guernsey Financial Services Commission (GFSC). There is no Alderney-specific crypto-asset licensing authority distinct from the GFSC. Alderney does, however, have its own sectoral gambling regulator, the Alderney Gambling Control Commission (AGCC), which licenses eCasinos under the Alderney eGambling Ordinance and Alderney eGambling Regulations 2009 but which has no remit over virtual-asset service provision as such. As of the most recent MONEYVAL assessment only one VASP was licensed Bailiwick-wide, a proof-of-concept reinsurance-linked token project restricted to institutional and wholesale clients, with demand for further licences expected to remain low.
This cycle brought a material easing to that framework: the Lending, Credit and Finance (Amendment) Rules, 2026, effective 1 October 2026, remove the requirement for a firm already licensed by the GFSC to hold a separate VASP licence in every case. This addresses a duplication under the prior regime, where firms holding another GFSC licence were nonetheless required to obtain a distinct VASP authorisation for virtual-asset activity. The pinpoint rule or paragraph number effecting this change has not yet been verified against primary rule text reaching this cycle, and the underlying confidence on this specific amendment is accordingly assessed as probable rather than confirmed.
Whether Alderney carries any variance from this Bailiwick-wide VASP regime, given the Alderney Gambling Control Commission's separate gambling-sector remit, has not been resolved in the material available this cycle. No AGCC-specific crypto-licensing instrument distinct from the GFSC's Part III regime was identified.
Outlook
The core Part III licensing requirement remains in force notwithstanding the October 2026 duplication-removal amendment. Primary-text confirmation of the amendment's precise mechanism, and resolution of whether any AGCC-administered variance applies to Alderney specifically, are the two open items most likely to affect this module going forward.
Crypto Licensing
The Guernsey Financial Services Commission regulates virtual asset service provider activity touching the Bailiwick of Guernsey, including Alderney, under the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022, as amended by the Lending, Credit and Finance (Amendment) Rules, 2026. On 9 September 2026 the Commission announced two changes to that regime, both effective 1 October 2026: it removed the blanket requirement for a firm already licensed by the Commission in another capacity to obtain a separate VASP licence, and it lifted the restriction that had previously confined VASPs to non-retail counterparties, allowing VASPs to serve retail customers. Both changes move in a liberalising direction, reducing duplicate licensing burden for existing licensees extending into crypto-asset activity and widening the addressable customer base for VASPs generally.
No instrument specific to Alderney, distinct from this Bailiwick-wide GFSC regime, has been found. The Alderney Gambling Control Commission's own published scope statement confirms that AGCC regulates eGambling exclusively and has no crypto-asset or VASP remit, which means the GFSC regime is the entire operative licensing framework for any VASP activity with an Alderney nexus; there is no parallel or supplementary Alderney-specific authorisation layer sitting alongside it. Whether incorporation in Alderney specifically, as opposed to incorporation elsewhere in the Bailiwick, carries any distinct supervisory treatment for a VASP applicant has not been confirmed either way.
Outlook
The narrowed perimeter is now in force. The next material marker for this module is confirmation, if any becomes available, of whether Alderney incorporation attracts distinct GFSC supervisory treatment for VASP applicants relative to Guernsey incorporation -- a question the Commission has not yet addressed on present evidence.
Sources and findings (13)
- T2FATF / MONEYVAL — A VASP licensing regime was introduced under the Lending, Credit and Finance Law applicable across the Bailiwick of Guernsey (including Alderney), with the licensing regime entering into force in July 2023. retrieved M5 binding in force
- T2FATF / MONEYVAL — As at the most recent national risk assessment, only one VASP was licensed in the Bailiwick of Guernsey (a proof-of-concept project set up by a re-insurance company providing insurance-linked virtual-asset tokens), and demand for further VASP licences was expected to remain low. retrieved M3 non-binding
- T2FATF / MONEYVAL — The GFSC is the licensing and supervisory authority for VASPs (and all other Bailiwick financial-services businesses, TCSPs and dealers in bullion), applying Bailiwick-wide including Alderney. retrieved M4 binding in force
- T2FATF / MONEYVAL — The AGCC is the authority tasked with the licensing of eCasinos in Alderney; it has no licensing remit over virtual-asset service providers, which remain exclusively a GFSC matter. retrieved M3 binding in force
- T2FATF / MONEYVAL — The AGCC relies almost exclusively on remedial actions for AML/CFT and licensing breaches in the eGambling sector and, during the MONEYVAL review period, never exercised its formal enforcement powers. retrieved M3 non-binding
- T2FATF / MONEYVAL — The GFSC holds wide-ranging remediation and enforcement powers across all Bailiwick-regulated sectors, including VASPs, and has exercised enforcement action against both regulated entities and senior officers, although the number of pecuniary fines imposed remains low relative to the volume of supervisory engagements. retrieved M3 binding in force
- T3Guernsey Financial Services Commission — Removed the blanket requirement for an already-licensed Commission firm to obtain a separate VASP licence and lifted the restriction preventing VASPs from serving retail customers; changes made 9 September 2026, effective 1 October 2026. retrieved M3 binding in force
- T1Alderney Gambling Control Commission — No Alderney-specific crypto-asset or VASP instrument distinct from the Bailiwick-wide GFSC regime was located; AGCC regulates only eGambling, not crypto-asset services. M2 non-binding
- T1Guernsey Financial Services Commission — Firms already licensed by the GFSC are no longer required in every case to hold a separate VASP licence to undertake virtual asset activity, effective 1 October 2026. M4 binding in force
- T1Guernsey Financial Services Commission — The blanket restriction preventing VASPs from offering services to retail customers was removed by the same 2026 amendment; retail VASP activity is now assessed case by case. M3 binding in force