Cape Verde, the Atlantic archipelago state, runs a FATF-aligned prior-registration regime for virtual-asset services: providing such services on a Cape Verde base is lawful only for an entity that has obtained prior registration with the Banco de Cabo Verde. The framework rests on two instruments — the 2023 law „30/X/2023“ and the central bank's 2024 notice „02/2024“, in force since 27 July 2024. Every fact on this page is drawn from the official gazette (boe.incv.cv), where both instruments are published; the bank's own website is not directly reachable from our network, so the gazette is the primary source we rely on — and we say plainly what that source does not yet publish.
Getting the nature of the regime right matters more than its label. Cape Verde issues a prior registration, not a prudential or banking licence: a registered person becomes an entity with anti-money-laundering and counter-terrorist-financing obligations, supervised and verified by the Banco de Cabo Verde, but it does not become a licensed financial institution. The law names the central bank as the single regulator and supervisor for virtual-asset activities — the securities regulator's authorisation catalogue carries no virtual-asset category at all. The duty applies even to a person who already holds another professional authorisation, and operating without registration attracts sanctions under the anti-money-laundering legislation.
Equally important is honesty about the two gaps: no state fee is fixed in either instrument, and no public register of registered providers has been published. Both points are addressed in detail below, and verifying them with the bank is part of the service we offer.
The Scope of Covered Services
Notice „02/2024“ lists covered services on the FATF pattern, and the list is broader than the law's own enumeration. It captures classic exchange models as well as platform-based and technical ones, and misjudging it is a common route into unregistered operation. If your model includes any of the categories below — alone or in combination — prior registration is required:
- exchange between fiat currency and virtual assets — purchase and sale for Cape Verdean escudo or any foreign currency with legal course;
- exchange between virtual assets, including through operating a trading platform;
- operating or providing virtual-currency automated teller machines (crypto ATMs);
- transfer services — moving virtual assets between wallets, accounts and addresses on a client's behalf;
- custody and safekeeping, including control of private keys and administrative management of clients' assets;
- participation in an issuer's offer or sale of virtual assets, including placement;
- investment advice on virtual assets and portfolio management under mandates.
The Territorial Trigger: Cape Verde Substance Is Unavoidable
The registration duty attaches in three situations: to legal persons constituted in Cape Verde; to persons domiciled there or maintaining a stable establishment; and to persons obliged to file an activity-start declaration with the Cape Verdean tax authority. In other words, the connection to the country must take a local form — a company, a domicile or a stable establishment — before the regime applies at all.
For a Georgian business group the conclusion is an honest one: you cannot enter this regime, or obtain the status of a registered provider, by operating from Georgia alone. Reaching the Cape Verdean market — or serving international clients through a Cape Verdean structure — requires a local company or a stable establishment: local management, premises and staff, and a functioning anti-money-laundering capability. There is no extraterritorial „promotion to residents“ hook of the kind some jurisdictions use, so the model must be built in the right order: genuine substance first, registration second.
The Filing: Documents, Business-Plan Content and Deadlines
The application is made in Portuguese and addressed to the central bank's microprudential supervision department. The contents of the file are prescribed in detail: the notification form together with fit-and-proper declarations for the members of management and top management; draft articles of association that expressly name the virtual-asset activities; and a programme of activity with a business plan.
The business plan itself must carry specific content: geographic implementation, organisational structure, human and technical means, a detailed description of the information-systems architecture, projected transaction volumes for each virtual-asset activity over the first 3 years, and the expected start date. The file is completed by an internal-control and anti-money-laundering risk assessment with the mitigating measures; identity, fitness and competence evidence for shareholders, beneficial owners and management bodies; and proof of share capital and of the origin of funds.
Foreign corporate documents must be apostilled under the Hague convention or legalised, accompanied by certified translations — for Georgian corporate documentation this means a double administrative layer that must be planned ahead. The decision is notified to the applicant within 90 days, and if the bank stays silent within that period the application is deemed refused: silence amounts to a tacit refusal. The absolute cap on the whole examination is 6 months from the initial filing. After registration, activity must actually start within 6 months or the registration lapses, and the start of activity is reported to the supervision department by e-mail — supervisao@bcv.cv.
Refusal grounds are named in advance: an incomplete file, false or inexact statements, unmet access requirements, and a grave risk of anti-money-laundering non-compliance. Adding a new type of virtual-asset activity or extending into higher-risk jurisdictions requires a full re-run of the initial procedure — so plan the model with future growth scenarios reflected in the first application.
Fees, Public Register and Sources — the Honest Picture
No state fee is set out either in the law or in the bank's notice — a published figure simply does not exist, and for that reason this page prints none. For realistic budgeting, plan for translation into Portuguese, apostille or legalisation, local representation and substance costs; whether any charge exists in practice is confirmed with the bank before filing.
The second honest unknown is market depth: a public register of registered virtual-asset providers does not yet exist. The bank's authorised-institutions pages show no virtual-asset category, and the notice imposes no duty to publish such a list — so official sources cannot tell how many providers, if any, have completed registration. Establishing the real picture requires a written request to the bank's supervision department — supervisao@bcv.cv — and that step is part of our service.
On sources, we are precise: the central bank's site does not open directly from our network, so every fact described here was verified against the official gazette (boe.incv.cv), where both the law and the notice are published. We deliberately do not describe an exact online filing route or invent portal steps — forms and channels are confirmed with the bank itself. A separate word on digital banks: that model is a distinct, heavier track governed by the full banking-licence regime, intended only for genuine banking models, and virtual-asset registration is no substitute for it.
The Legal Layer for a Georgian Group
Planning a Cape Verdean structure from Georgia unfolds in two layers. The first is group architecture: whether to incorporate a Cape Verdean subsidiary or open a branch and stable establishment, who the shareholders and beneficial owners will be, how governance is divided between Tbilisi and Cape Verde, and how the structure fits the group's overall governance framework. The second is cross-border operation: the form in which the Cape Verdean entity serves clients on Georgian and other markets, and how that form stands up to the expectations of both regulators.
General legal principles do the work here, and they need dedicated planning: the Georgian side of the group retains its own corporate, tax and anti-money-laundering obligations in the Georgian entities; the documentary relationship between the Cape Verdean and Georgian persons — intercompany agreements and service-level arrangements — and the data flows between them must be built so that both regulators' expectations are met without friction. The centre of gravity is the reality of substance: a paper-thin Cape Verdean person puts both the registration itself and the group's tax and reputational position at risk.
Frequently Asked Questions
Is Cape Verde's registration a crypto licence?
No — terminology matters. Cape Verde grants prior registration, which records your entity as a subject of anti-money-laundering supervision; it is not a prudential licence and does not turn your company into a financial institution. The centre of gravity of the requirements is client due diligence, risk assessment and internal control rather than banking capital rules.
Can we register with only a Georgian company?
No. The duty engages only if you are constituted in Cape Verde, domiciled there or maintain a stable establishment — otherwise you are not a subject of this regime at all. A group operating through a Cape Verde base must first build local substance: a company, management and an anti-money-laundering function.
How long does the decision take, and what happens in case of silence?
The decision is notified within 90 days; if the bank does not respond in that period, the application is deemed refused — a presumption of tacit refusal. The absolute cap on the examination is 6 months, which is why the file must be complete and precise from the outset.
What is the state fee for the application?
None is published — neither the law nor the notice fixes a figure, so no number is printed here. Exact terms are confirmed with the supervision department — supervisao@bcv.cv — before filing; budget for translation, apostille and substance costs in the meantime.
Where can we check who is already registered?
A public list does not exist yet — the bank's pages show no virtual-asset category, and how many providers have completed registration is unknown from official sources. The real picture is established by a written request to the supervision department, and that verification is part of our work.
How We Help on Legal.ge
The Legal.ge team walks the full cycle with you: we assess whether your model engages Cape Verde's territorial trigger and service list; plan substance and group structure; prepare the draft articles, the business plan — with the 3-year volume projections and the description of your IT architecture — and the anti-money-laundering risk assessment; put a precise schedule on Portuguese translation and apostilles; and after filing, handle the correspondence with the bank, including supervisao@bcv.cv. Decide on official facts — contact us on Legal.ge.