El Salvador DASP registration.
A structured route for businesses providing broader digital-asset services under the Digital Assets Issuance Law and the supervision of the National Commission of Digital Assets.
The framework is broader than a conventional crypto exchange licence.
A DASP may be a person or entity whose ordinary business involves one or more covered digital-asset services and that is either domiciled in El Salvador or actively markets those services to potential clients in the country.
Exchange & trading venues
Exchange of digital assets for fiat or other digital assets, and operation of exchange platforms or markets for digital assets or derivatives.
Custody & administration
Safeguarding, custody, or administration of digital assets or the means used to access or control them.
Transfers
Transfer of digital assets or access/control mechanisms between persons, wallets, acquirers, or digital-asset accounts.
Orders & derivatives
Reception, transmission, or execution of buy and sell orders, including certain digital-asset derivative activities.
Issuance support & placement
Risk and price evaluation, underwriting, placement, and related services for qualifying digital-asset issuances.
Investment & financing products
Promotion, structuring, and management of digital-asset investment products, loans, funds, or financing structures, subject to approved scope.
Pre-registration first, definitive registration second.
CNAD’s published route begins with a preliminary review of the applicant and intended operating area, followed by a final registration phase once the project receives a no-objection direction and the required documentation is assembled.
Scope and operating map
Identify the exact Article 19 activities, client groups, countries, transaction flows, custody model, technology, and third parties.
Entity, ownership, and governance
Prepare the company, shareholder and beneficial-owner information, directors, legal representation, organizational structure, and key-personnel evidence.
CNAD pre-registration
Submit the initial applicant and business-model information for CNAD’s review, respond to questions, and address any requested additions.
Definitive application
File the complete registration set, including policies, manuals, business and technical materials, corporate documents, and supporting evidence.
Resolution, registration, and launch
Following a favorable resolution and completion of formalities, CNAD issues the registration certificate and authorization to operate within the approved scope.
The application must be backed by a real operating framework.
Business plan
Services, markets, customers, revenue logic, projected scale, operating structure, and three-year implementation narrative.
AML/CFT controls
Risk assessment, onboarding, due diligence, sanctions screening, monitoring, escalation, reporting, and records.
Governance & personnel
Directors, managers, legal representation, compliance functions, fit-and-proper evidence, responsibilities, and reporting lines.
Technology & cybersecurity
System architecture, access controls, wallet or custody model, incident response, continuity, outsourcing, and security manuals.
Customer & asset protection
Disclosures, complaint handling, segregation logic where applicable, key management, transaction authorization, and operational controls.
Ongoing supervision
Reporting calendars, audit and accounting coordination, policy refresh, regulator communications, and material-change management.
What should be decided before drafting documents?
The law can reach non-domiciled providers that actively promote or market covered services to potential clients in El Salvador. Territorial reach should be reviewed before launch or marketing.
No. DASP is the broader CNAD route under the Digital Assets Issuance Law. Bitcoin-specific activities may also point to the BCR’s Bitcoin Service Provider registry. Some models may require coordinated analysis of both.
No blanket tax conclusion should be made from the licence alone. The law provides tax benefits for qualifying participants and transactions, but eligibility, effective date, entity treatment, source of income, and cross-border consequences require professional tax analysis.
Much of the project can be coordinated remotely, but local corporate formalities, physical filing requirements, legal representation, banking, personnel, or regulator meetings may require local execution.
Define the approved activity scope before building the application.
Share the business model, customer journey, markets, asset flows, custody, technology, and current company status.