VATP Virtual Assets Trading Platform

A master reference on VATPs, VASPs and global virtual asset hubs

1. Executive Summary

Virtual Asset Trading Platforms (VATPs) have evolved from crypto-native exchanges into regulated market infrastructures that sit at the heart of the emerging tokenised economy. A modern Virtual Assets Trading Platform is no longer just a website for buying and selling coins: it is a tightly supervised environment that brings together trading, custody, settlement, market surveillance and investor protection for an increasingly broad spectrum of Virtual Assets.

Globally, policymakers are converging on similar concepts, even if the labels differ:

• Hong Kong has built one of the world’s most comprehensive VATP frameworks, combining dual licensing under the Securities and Futures Ordinance (SFO) and the Anti–Money Laundering and Counter–Terrorist Financing Ordinance (AMLO), with detailed rulebooks for VATP operators.
• Dubai (VARA) has created a dedicated Virtual Assets Regulatory Authority, which regulates virtual asset activities across the Emirate (outside DIFC) through a bespoke law and modular rulebooks.
• Abu Dhabi (ADGM), via its Financial Services Regulatory Authority (FSRA), was one of the first to implement a comprehensive virtual asset framework for exchanges, brokers, custodians and other VASPs.
• Singapore regulates virtual asset activity largely through its Digital Payment Token (DPT) and Digital Token Service Provider (DTSP) regimes, under the Payment Services Act and the Financial Services and Markets Act.
• The British Virgin Islands (BVI) has enacted the Virtual Assets Service Providers Act 2022 (VASP Act), which establishes a registration regime and ongoing obligations for VASPs operating in or from the territory.

This report brings together the most current information from these regimes and synthesises it into a single reference on VATP and Virtual Assets Trading Platforms: what they do, how they are regulated, and how major hubs are positioning themselves for a future where tokenised assets, stablecoins, NFTs, domain name assets and RWAs coexist on regulated platforms.

2. Foundations: Virtual Assets, VATPs and VASPs

2.1 What Are Virtual Assets?

“Virtual assets” is now a widely adopted umbrella term. In line with FATF and many local statutes, a Virtual Asset is typically defined as a digital representation of value that is:

• Cryptographically secured;
• Used or intended to be used as a medium of exchange, a store of value or for investment; and/or
• Provides governance or other rights in relation to a protocol or arrangement;
• And can be transferred, stored or traded electronically.

This concept covers:

• Layer-1 and Layer-2 cryptocurrencies (e.g. BTC, ETH, SOL)
• Stablecoins and payment tokens
• Governance tokens and utility tokens
• Security tokens and tokenised securities (often within a separate securities law perimeter)
• Real World Asset (RWA) tokens, such as tokenised real estate or private credit
• NFT-type assets representing IP or in-game items
• Emerging assets such as Domain Name Virtual Assets, where domain ownership is tokenised and traded like digital real estate

At the same time, regulators explicitly exclude:

• Traditional fiat in digital form
• Central bank digital currencies (CBDC)
• E-money/stored value facilities
• Closed-loop loyalty and in-game points

2.2 VATP vs VASP: Two Related but Distinct Ideas

FATF uses the term Virtual Asset Service Provider (VASP) to cover a wide category of businesses that handle or intermediate virtual assets for others—exchanges, brokers, custodians, and certain DeFi-like facilitators. VASP is the term adopted by many jurisdictions, including the BVI’s VASP Act 2022.

A VATP, by contrast, is a more specific subtype of VASP: a centralised trading venue that:

• Maintains an order book or matching engine;
• Facilitates regular buying and selling of Virtual Assets between participants;
• Often provides integrated custody and settlement services.

Put simply:

• All VATPs are VASPs, but not all VASPs are VATPs.
• VATPs are closer to “exchanges + CSD/custodian” in the traditional world, whereas VASPs also include brokers, dealers, payment providers and certain wallet operators.

2.3 Core Functions of a Virtual Assets Trading Platform

Across Hong Kong, ADGM, Singapore, Dubai and BVI, a mature VATP tends to perform the same core functions:

1. Client Onboarding & KYC
2. Trading & Price Discovery
3. Custody & Settlement
4. Surveillance & Risk Management
5. Governance & Reporting

3. Hong Kong: Flagship VATP Regime

Hong Kong is widely regarded as one of the most fully developed regulatory environments for VATPs. Under its dual regime:

• AMLO regulates centralised VA exchanges (VATPs) dealing in non-security VAs and performing VA custody;
• The SFO regulates platforms dealing in security tokens and providing automated trading services, requiring Type 1 and Type 7 licences.

In 2025, the SFC published its ASPIRe roadmap—“Access, Safeguards, Products, Infrastructure, Relationships”—which sets out 12 initiatives to strengthen Hong Kong’s virtual asset market, including work on stablecoins, VA intermediaries, custody, derivatives and broader tokenisation infrastructure.

For an authoritative overview, see the Virtual Asset Trading Platform Operators section on the
Securities and Futures Commission of Hong Kong (SFC).

4. UAE: Dubai VARA and Abu Dhabi ADGM

The United Arab Emirates is unique in that it hosts two major virtual asset hubs with complementary approaches: Dubai (VARA) and Abu Dhabi (ADGM).

Together, Dubai VARA and ADGM FSRA have effectively positioned the UAE as a dual-hub for regulated Virtual Assets and VASP activity across the region.

5. Singapore: Digital Tokens, DPTs and DTSPs

Singapore’s approach centres on payment and market-intermediary regulation under the Payment Services Act 2019 (PSA) and the Financial Services and Markets Act (FSMA).

6. British Virgin Islands: Offshore VASP Hub

The British Virgin Islands’ Virtual Assets Service Providers Act 2022 (VASP Act), in force since February 2023, establishes a registration and supervisory framework for VASPs operating in or from the BVI.

7. Comparative Analysis: Five Major Hubs for VATPs and VASPs

8. Strategic Considerations for Building or Using a VATP

8.1 Designing a Compliant VATP

Whether in Hong Kong, Dubai, ADGM, Singapore or BVI, a serious VATP must treat regulation and risk management as design constraints, not afterthoughts:

• Build the trading, custody and risk engines with regulatory requirements in mind from day one, rather than bolting on controls later.
• Treat token-listing and de-listing as full governance events, with clear criteria and documentation.
• Assume that regulators will, over time, converge on higher standards for custody, segregation, proof-of-reserves, Travel Rule implementation, and staking/lending products.

8.2 Leveraging Multi-Hub Strategies

Many sophisticated businesses will adopt a multi-hub strategy:

• Use Hong Kong for institutional cash and derivatives markets and tokenised securities;
• Use VARA / ADGM for regional expansion, cross-border order books and integrated VA activity;
• Use Singapore for payment-centric digital token flows and banked relationships;
• Use BVI for group-level structuring of VASPs and special-purpose vehicles.

8.3 Preparing for the Tokenised Future

9. Conclusion: VATPs as the Trading Layer of the Tokenised Economy

The concept of a VATP Virtual Assets Trading Platform sits at the intersection of technology, regulation and market structure. In a few short years, regulators in Hong Kong, Dubai, Abu Dhabi, Singapore and the BVI have:

• Moved from uncertainty to clarity in defining Virtual Assets, VATPs and VASPs;
• Built licensing, conduct and AML/CFT frameworks explicitly tailored to Virtual Assets;
• Started to integrate tokenisation, stablecoins and shared global liquidity into mainstream financial regulation.

As tokenisation extends to securities, funds, RWAs, domain names and IP, the role of Virtual Assets Trading Platforms will only grow. VATPs are fast becoming:

• The universal matching engines for value in digital form,
• The custodial layer that secures tokenised assets,
• And the compliance perimeter through which regulators can supervise an otherwise borderless, 24/7 digital asset market.

Visual Appendix: VATP.IO™ gallery