[Exclusive] BSP: Crypto-to-Crypto Trading 'Fits Naturally' Under SEC; VASP Rule Amendments Planned

Regulatory perimeter is moving toward market structure

The key point is not that crypto trading is being newly discovered by regulators. It is that the BSP is separating two functions that often blur inside marketplaces:

• value conversion — closer to money-changing, payments, and foreign-exchange logic;
• investment-driven trading — closer to order books, intermediation, and speculative market activity.

According to the BitPinas report, the BSP said that before the SEC issued Memorandum Circular Nos. 4 and 5 of 2025, crypto-to-crypto exchanges were handled under the same framework used for money-changing and foreign-exchange dealing. The central bank treated the transaction as value conversion, regardless of the underlying digital asset.

That framing changes once a venue runs order-book trading or intermediation. The BSP said speculative crypto-to-crypto exchange through a trading venue fits under the SEC perimeter. The data point for marketplace participants is simple: execution venue design now matters.

An NFT platform that only supports wallet-to-wallet settlement has a different risk profile from a platform that routes swaps, aggregates liquidity, or embeds token trading. The more the platform resembles a venue with matching, routing, or investment execution, the more likely the regulatory analysis shifts away from simple conversion.

VASP amendments could tighten counterparty checks

The BSP plans to release proposed amendments to Circular No. 1108 for public comment. The reported objective is to reflect updates in the regulatory split between BSP-supervised VASP activity and SEC-supervised market activity.

The practical checkpoint is the “unbroken chain” rule. BitPinas asked about a model where a licensed domestic VASP routes transactions to a global platform regulated by the Financial Services Regulatory Authority of the Abu Dhabi Global Market. In that scenario, the BSP said both domestic and foreign entities are expected to maintain and hold transaction, sender, and beneficiary information.

For trading desks, NFT marketplaces, and wallet-integrated services, this creates a compliance test around routing architecture:

• Who holds sender and beneficiary data?
• Where does the transaction record break, if it breaks?
• Is the foreign counterparty reviewed with sufficient due diligence?
• Which part of the flow touches fiat rails?

The BSP also stated that its rules remain anchored on Financial Action Task Force guidance around anti-money laundering and payments risk, while the SEC draws from IOSCO standards. That split is important. FATF logic follows transaction traceability. IOSCO logic follows market conduct and trading infrastructure.

A marketplace can therefore face two different control surfaces: AML data continuity on one side, market-activity classification on the other.

Sandbox access is not a regulatory bypass

The clarification comes amid questions around Binance’s return to the Philippines through an SEC Strategic Sandbox arrangement involving BlockShoals Technologies, as described in a whitepaper from legal counsel Arden Consult. The BSP said it defers to the SEC on sandbox requirements and implementation.

But the limiting language matters. Participation in the SEC Strategic Sandbox does not exempt entities from applicable laws and regulations. VASP activities and fiat transaction rails remain within the BSP’s scope. Domestic VASPs that partner with sandbox participants remain subject to standard BSP regulatory and supervisory mandates.

That is the operating risk for platforms watching this market. A sandbox may test product structure. It does not automatically neutralize counterparty risk, fiat settlement obligations, or VASP supervision.

A separate report from Livemint said Russia’s Alfa Bank has begun testing crypto trading in its brokerage app with a small group of qualified investors and is considering a broader suite of crypto services after local regulation is approved. Livemint said it could not independently verify the reports. Still, the direction is consistent: regulated financial institutions are testing crypto access, but distribution remains gated by rulebooks, investor classification, and custody definitions.

For NFT liquidity, the takeaway is strict. Track the venue function, not the brand name. If a platform adds token swaps, routing, or order-book execution, traders should treat regulatory exposure as part of slippage analysis: invisible until liquidity exits, banking access narrows, or counterparties stop settling.