CHAPTER 12 / 55 · Paid
FS-1.14 Custodian services (digital asset).
Follow a promoter’s old slide, stop, and reconcile the directory, GN 119, the 2019 Rules and VAITOS Class R before anyone files.
Approx. 20 min with exercisesLaw cut-off: 20 September 2026Our approach
By the end of this chapter
- Describe the shop in one paragraph from the first file on the desk.
- Decide the promoter’s next asks: which stay on this letter, which need another paper.
- Keep neighbouring permissions off this desk.
- Cite the enabling section and treat the licence letter as the book.
FSC · FS-1.14 · Licence (directory row; Gazette status unresolved)
1. the promoter with the old slide’s shop
A promoter wants to safekeep tokenised assets in Mauritius and has copied FS-1.14 from an old slide. The FSC web directory still lists “Custodian services (digital asset)”. The 2019 Rules still describe a safekeeping book. Neither fact, by itself, proves that the Commission currently issues the licence.
This chapter is a stop. Reconcile the directory, GN 119 and VAITOS Class R before anyone files.
The three facts that have to stay true of the file:
1. Second Schedule Part I as reviewed for this course does not list the activity. 2. The 2019 Rules, rule 4(1), still say no person shall carry out custody services for digital asset in Mauritius without this licence — and rule 4(3) limits objects to safekeeping. 3. VAITOS Class R is a different statute. Do not collapse the three.
The FSA Second Schedule Part I reviewed for this course (including the GN 19 of 2024 spot-commodity insertions) does not list “Custodian services (digital asset)”. The activity is therefore not, on that print, a named Part I financial business activity.
Financial Services Act 2007 (directory family) · Financial Services (Custodian services (digital asset)) Rules 2019, Directory row under Financial Service Providers; enabling section not printed on the 1 July 2026 web table; 2019 Rules made under section 93. See the register note · Open the published text ↗.
2. A week with the digital-custodian term sheet
Monday. The slide is photocopied onto a term sheet. The student red-lines it: directory row, Gazette schedule, 2019 Rules, Class R.
Tuesday. GN 119 as reviewed does not carry the FS-1.14 fee line. The directory still prints processing Rs 175,000 / annual Rs 350,000. Those figures are not certified as a current Gazette fee.
Wednesday. The criteria column on the 1 July 2026 directory page captured for the inventory is blank.
Thursday. Counsel writes the options: wait for reconciliation, or consider Class R if the assets are virtual assets under VAITOS.
Friday. Nobody files. The week’s work was the stop. That is what this code is used for in this course.
The other files on this desk should look like that first one: a named person, a specified activity, and a letter that matches the work. That is what FS-1.14 is used for. The Act matters when the promoter with the old slide applies, when the Commission writes conditions onto the letter, and when the same promoter telephones with a different idea.
3. What the same promoter asks next
The facts are fictional. The method is the course: keep the shop you have just watched, and ask which desk is now doing the work.
Look next door
Stop and reconcile before anyone files
A promoter has copied FS-1.14 from an old slide and wants a Mauritius digital-custodian letter this month.
What to check. Availability is unresolved. Reconcile the directory, GN 119, the 2019 Rules and VAITOS Class R.
Different paper
Treat the slide as a current permission
“It is still on the website, so we can apply tomorrow.”
Why it does not. The web directory is not proof that the licence is issuable. It is not proof of repeal either.
Different paper
Use Class R and FS-1.14 as one letter
Tokenised assets, one vault, two labels.
Why it does not. Class R is VAITOS section 7. FS-1.14 is a directory row with a 2019 Rules book. They are not substitutes.
| The promoter asks the promoter with the old slide to… | This licence? | Why |
|---|---|---|
| Stop and reconcile before anyone files | Look | Availability is unresolved. Reconcile the directory, GN 119, the 2019 Rules and VAITOS Class R. |
| Treat the slide as a current permission | No | The web directory is not proof that the licence is issuable. It is not proof of repeal either. |
| Use Class R and FS-1.14 as one letter | No | Class R is VAITOS section 7. FS-1.14 is a directory row with a 2019 Rules book. They are not substitutes. |
4. Papers that sit beside this one
Not VA-1.3 Virtual Asset Custodian (Class R) under VAITOS section 7, and not FS-1.7 non-CIS custody. Do not invent an applicant type as currently issuable.
Neighbouring codes have their own chapters. Do not import their books into this letter.
5. The letter and the file
Unknown as an operational class until the directory/Gazette mismatch is reconciled. A letter of intent under the 2019 Rules is not a promise to grant. Status remains unresolved at cut-off 20 September 2026.
Permitted activities — the sections
The FSA Second Schedule Part I reviewed for this course (including the GN 19 of 2024 spot-commodity insertions) does not list “Custodian services (digital asset)”. The activity is therefore not, on that print, a named Part I financial business activity.
Financial Services (Custodian services (digital asset)) Rules 2019, rule 4(1): “No person shall carry out custody services for digital asset in Mauritius without a Custodian services (digital asset) licence issued by the Commission.” Rule 4(3): “The objects of a custodian under these rules shall be limited to the safe-keeping of digital asset and operations arising directly from it.”
Rule 2: “custody” means the safekeeping of digital asset being held or transacted. “Digital asset” is defined there (token in electronic or binary form; digital representation of value used as a medium of exchange, representing debt or equity, or providing access to a blockchain-based application) and excludes loyalty value that cannot be exchanged for legal tender and in-game value.
VAITOS Class R (section 7) is a different statute. Non-CIS custody of ordinary assets is FS-1.7. Do not collapse the three.
Licensing conditions — the sections
2019 Rules, rule 4(2): application in accordance with Part IV of the Act (section 16 and section 18). Rule 5: a letter of intent may issue first; it is not a promise to grant. The applicant must, within six months of the letter of intent, demonstrate resources, infrastructure and staffing; the licence, if granted, requires commencement within six months.
Rule 6: an office in Mauritius from which core functions are performed, and a sufficiently senior representative in Mauritius. Rule 7: board of at least three directors, of which at least 30 per cent independent and one resident in Mauritius; registered office and place of business in Mauritius.
Directory fees (processing Rs 175,000 / USD 5,000; annual Rs 350,000 / USD 10,000) were not found in the GN 119 replacement First Schedule reviewed for this course. The criteria column on the 1 July 2026 directory page captured for the inventory is blank. Status remains unresolved.
Who may hold it. Unknown as an operational class until the directory/Gazette mismatch is reconciled. The 2019 Rules describe a custodian entity; do not invent an applicant type as currently issuable.
Published criteria. No dedicated criteria PDF is treated as current for this course. The directory criteria column for FS-1.14 is blank on the 1 July 2026 page captured for the inventory. VAITOS Class R has its own criteria. The 2019 Rules remain the last dedicated instrument describing the book.
Rules, codes and circulars. No circular in the cut-off set is treated as confirming that FS-1.14 remains issuable or that it has been repealed. CL20260107 concerns the 1 July 2026 fee review generally. The 2019 Rules have not been treated as a VAITOS Class R substitute.
6. How to cite FS-1.14
| Coordinate | As at 20 September 2026 |
|---|---|
| Directory code | FS-1.14 Custodian services (digital asset) |
| Legal nature | Licence (directory row; Gazette status unresolved) |
| Enabling law | Financial Services Act 2007 (directory family) · Financial Services (Custodian services (digital asset)) Rules 2019 · Directory row under Financial Service Providers; enabling section not printed on the 1 July 2026 web table; 2019 Rules made under section 93 |
| Fees as at 1 July 2026 | Directory: processing Rs 175,000 (USD 5,000); annual Rs 350,000 (USD 10,000). These figures were not found in the GN 119 replacement First Schedule reviewed for this course. Do not collect or quote them as a certified current Gazette fee without reconciling the schedule. |
| Status at cut-off | Unresolved. The web directory lists the code; GN 119 as reviewed does not; Second Schedule Part I as reviewed does not. The 2019 Rules still exist. This row is not proof of an available licence and not proof of repeal. |
The structured library card keeps the same coordinates for search. Open FS-1.14 in the reference library.
FSC codified list of licences, authorisations, approvals, recognitions and registrations ↗Register noteFinancial Services Act 2007 ↗Register noteFSC licensing and fees amendment rules 2026 ↗Register noteFSC Circular Letter CL20260107 — review of fees and renewal of licences ↗Register noteFSC rules and regulations directory ↗Register noteFinancial Services (Custodian services (digital asset)) Rules 2019 ↗Register noteVirtual Asset and Initial Token Offering Services Act 2021 ↗Register noteFSC licensing and fees amendment rules 2026 ↗Register note
PAUSE & REFLECT
Check your understanding.
Three questions to make the ideas stick. Your score is saved on this browser; this is a learning exercise, not a qualification.
Follow the sources.
Each title opens the published text. The register note records the edition used for this course.
- FSC codified list of licences, authorisations, approvals, recognitions and registrations ↗ All published category codes, fees, forms and licensing-criteria columns; consolidation as at 1 July 2026 · Register note
- Financial Services Act 2007 ↗ Sections 2, 14, 14A, 16–18, 25, 33, 71A, 72, 77, 77A, 77B, 77C, 78, 79A; Second Schedule Parts I–III; Fifth Schedule · Register note
- FSC licensing and fees amendment rules 2026 ↗ Rule 3 and replacement First Schedule; rule 4 commencement · Register note
- FSC Circular Letter CL20260107 — review of fees and renewal of licences ↗ 1 July 2026 fee review; annual-fee due date 30 September 2026; FSCOne alternative arrangements · Register note
- FSC rules and regulations directory ↗ Consolidated licensing and fees rules; sector-specific rules including Securities (Licensing) Rules and Family Office Rules · Register note
- Financial Services (Custodian services (digital asset)) Rules 2019 ↗ Rules 2, 4–7; GN 44 of 2019 · Register note
- Virtual Asset and Initial Token Offering Services Act 2021 ↗ Section 7 (VASP licence); section 23 (ITO registration) · Register note
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