Unlocking the Role of a “Virtual Asset Service Provider” in Botswana: A Comprehensive Overview

In the intricate landscape of virtual finance, a key player defined by the Virtual Assets Act 2022 in Botswana is the “virtual asset service provider.” Let’s delve into the nuances of this definition:

Virtual Asset Service Provider:

A “virtual asset service provider” refers to a person who:

(a) Provides Virtual Asset Services on Behalf of Another Person:

  • Engages in virtual asset services under an agreement.
  • Undertakes these services as part of a business.
  • Acts on behalf of another person, offering specialized services within the virtual asset domain.

(b) Functions as a Dealer or Willing to Deal in Virtual Assets:

  • Operates independently, either as a dealer or with the intent to deal in virtual assets.
  • Engages in buying and selling virtual assets based on prices set by the person.


The term “virtual asset service provider” is broad and encompasses a variety of roles, including:

  • (i) Market Maker or Liquidity Provider:
    • Individuals or entities facilitating liquidity in the market.
    • Market makers ensure there is a ready market for buying and selling virtual assets.
  • (ii) System Providing Virtual Liquidity:
    • Platforms or systems that contribute to virtual liquidity.
    • Allows traders to seamlessly engage in buying and selling derivatives on the blockchain.
  • (iii) Virtual Automated Market Maker:
    • Entities leveraging automated processes for market-making activities.
    • Enhances efficiency in buying and selling virtual assets through automated mechanisms.

Regulatory Implications:

The inclusion of various roles under the umbrella of “virtual asset service provider” reflects the dynamic nature of the virtual finance sector. This definition ensures that entities offering services related to virtual assets, whether through direct trading or facilitating market dynamics, fall within the regulatory ambit.


Understanding the multifaceted roles covered by the term “virtual asset service provider” is crucial for industry participants, regulatory authorities, and stakeholders. It sets the stage for a well-defined regulatory framework that promotes transparency, accountability, and responsible practices in the burgeoning virtual finance ecosystem of Botswana.

As the digital landscape continues to evolve, the role of virtual asset service providers will play a pivotal part in shaping the future of financial services.