Peru VASP lawyer
US and Peruvian virtual-asset-service-provider matters require counsel who understand both the US regulatory framework administered by FinCEN under the Bank Secrecy Act and the Peruvian regulatory environment in which the VASP operates. Law Offices of SRIS, P.C., a US law firm founded in 1997, advises clients on the US-law dimensions of cross-border VASP compliance, registration, and transactional structuring where Peru is the foreign jurisdiction. The firm’s US-admitted attorneys handle the US regulatory side — FinCEN registration, BSA/AML program requirements, and federal securities-law analysis — while collaborating with Martín Mayandía, Of Counsel, admitted to practice law in Peru (2009) and not admitted in any US state bar, on matters of Peruvian law. For a consultation on your cross-border VASP matter, reach Law Offices of SRIS, P.C. at (888) 437-7747.
What a Peru VASP lawyer addresses on the US-law side
A VASP — virtual asset service provider — that touches the United States or US persons must navigate a multi-agency regulatory landscape anchored by the Bank Secrecy Act (31 U.S.C. § 5311 et seq.) and its implementing regulations at 31 C.F.R. Chapter X. FinCEN, the Financial Crimes Enforcement Network of the US Department of the Treasury, treats certain virtual-currency businesses as money services businesses (MSBs) subject to registration, anti-money-laundering program requirements, suspicious-activity reporting, and recordkeeping obligations. A VASP operating in or from Peru that serves US customers, processes US-dollar-denominated transactions, or otherwise has a US nexus may trigger these obligations regardless of where the entity is incorporated.
The US regulatory picture also includes the securities-law dimension: whether a particular digital asset constitutes a security under the Securities Act of 1933 and the Securities Exchange Act of 1934 is a threshold question that affects registration, exemption, and offering-structuring decisions. The Commodity Futures Trading Commission asserts jurisdiction over certain digital assets as commodities under the Commodity Exchange Act. A cross-border VASP matter may also implicate state-level money-transmitter licensing in New York, Virginia, or other states where the VASP has customers. Each of these frameworks carries its own registration triggers, exemptions, and ongoing compliance obligations. The analysis is fact-specific and depends on the VASP’s business model, the assets it handles, and the jurisdictions in which it operates.
How Mr. Sris and the firm’s Peru Of Counsel handle cross-border VASP matters
Cross-border VASP representation at Law Offices of SRIS, P.C. is structured with a clear jurisdictional division: the firm’s US-admitted attorneys handle all US regulatory, registration, and compliance work, while Martín Mayandía, Of Counsel, admitted to practice law in Peru (2009) and not admitted in any US state bar, addresses the Peruvian-law dimensions of the matter. This division is not merely a practice — it is required by the unauthorized-practice-of-law rules in both countries. Mr. Sris, admitted in Virginia, Maryland, the District of Columbia, New Jersey, and New York, serves as the responsible US attorney on every engagement. Mr. Mayandía’s role is limited to Peru-law matters in collaboration with the US-admitted attorneys of the firm.
On a typical cross-border VASP engagement, the US side may involve FinCEN MSB registration analysis, BSA/AML program design and documentation, securities-law classification of the digital assets at issue, state money-transmitter licensing strategy, and transactional structuring for token offerings or VASP acquisitions. The Peru side — handled by Mr. Mayandía — may involve Peruvian corporate structuring, regulatory registration with Peruvian authorities, and local compliance obligations. The two sides collaborate as needed, but each attorney practices only in the jurisdiction where they are admitted. The firm does not hold a location in Peru; all US-law work is handled from the firm’s Virginia principal location, by appointment only, and Mr. Mayandía practices from his own independent location in Peru.
About Mr. Sris and the sriscounsel Of Counsel network
Mr. Sris, Owner and Founder of Law Offices of SRIS, P.C., is a former prosecutor admitted to practice law in Virginia, Maryland, the District of Columbia, New Jersey, and New York. He founded the firm in 1997 and has built a cross-border practice serving international clients with US legal needs. Mr. Sris testified before the Virginia House Courts of Justice Committee in support of 2019 HB 635 (chief patron Del. David Bulova), the bill that became the 2019 revision to Va. Code § 20-107.3(g). On VASP and banking-and-finance matters with a Peru nexus, Mr. Sris leads the US regulatory and compliance work, drawing on decades of experience with federal and state financial-regulation frameworks.
For the Peru-law side of cross-border VASP engagements, the firm works with Martín Mayandía, Of Counsel, admitted to practice law in Peru (2009) and not admitted in any US state bar. Mr. Mayandía’s practice with Law Offices of SRIS, P.C. is limited to matters of Peruvian law and to serving as a liaison for international clients with the US-admitted attorneys of the firm. Mr. Sris and his Of Counsel bring extensive combined legal experience across US and Peruvian regulatory environments. The firm has no employees; every attorney other than Mr. Sris serves in an Of Counsel capacity.
Frequently Asked Questions
What is a VASP, and when does a Peruvian VASP trigger US regulatory obligations?
A virtual asset service provider (VASP) is a business that exchanges, transfers, safeguards, or administers virtual assets — a category that includes cryptocurrency exchanges, custodial wallet providers, and certain DeFi platforms. A Peruvian VASP triggers US regulatory obligations when it has a US nexus: serving US customers, processing transactions in US dollars through US correspondent banks, maintaining US-based servers or personnel, or marketing its services to US persons. Under the Bank Secrecy Act and FinCEN’s regulations at 31 C.F.R. Chapter X, a foreign-located MSB that does business wholly or substantially in the United States may be required to register with FinCEN and maintain an AML compliance program. The analysis is fact-intensive and depends on the VASP’s specific activities, customer base, and transaction flows. For guidance on your specific cross-border VASP situation, reach Law Offices of SRIS, P.C. at (888) 437-7747.
Do I need both a US-admitted attorney and a Peru-admitted attorney for a cross-border VASP matter?
Yes — a VASP operating across the US-Peru border typically requires counsel admitted in each jurisdiction because the regulatory frameworks are distinct and no single attorney is licensed to practice law in both countries. The US-admitted attorney handles FinCEN registration, BSA/AML compliance, securities-law analysis, and state money-transmitter licensing. The Peru-admitted attorney handles Peruvian corporate law, local regulatory registration, and Peruvian compliance obligations. Law Offices of SRIS, P.C. provides both through Mr. Sris (US-admitted) and Martín Mayandía, Of Counsel, admitted to practice law in Peru (2009) and not admitted in any US state bar. Each attorney practices only in the jurisdiction where they are admitted, and the two collaborate as the matter requires. This structure ensures competent representation on both sides of the border without any unauthorized practice of law.
What US regulatory agencies oversee VASP activities with a Peru nexus?
Several US federal and state agencies may assert jurisdiction over a VASP with a Peru nexus, depending on the nature of the virtual assets and the services provided. FinCEN, under the Bank Secrecy Act, regulates VASPs that qualify as money services businesses. The Securities and Exchange Commission asserts jurisdiction where a digital asset is deemed a security under the Securities Act of 1933. The Commodity Futures Trading Commission regulates certain digital assets as commodities. At the state level, money-transmitter licensing requirements in New York, Virginia, and other states may apply. The specific agencies involved depend on the VASP’s business model and the assets it handles. To discuss the details of your international VASP matter, contact Law Offices of SRIS, P.C. at (888) 437-7747.
How does the firm structure the attorney-client relationship for a cross-border VASP engagement?
Law Offices of SRIS, P.C. enters into the attorney-client relationship as the US law firm, with Mr. Sris serving as the responsible US attorney. The engagement letter specifies that the firm’s US-admitted attorneys handle all US-law aspects of the representation. For Peru-law matters, the firm engages Martín Mayandía, Of Counsel, admitted to practice law in Peru (2009) and not admitted in any US state bar, whose role is limited to Peru-law matters in collaboration with the US-admitted attorneys of the firm. The client receives clear documentation of which attorney handles which jurisdictional component. This structure complies with the unauthorized-practice-of-law rules in both the United States and Peru and ensures that the client has competent counsel on each side of the border. For a consultation on cross-border VASP counsel, reach Mr. Sris and his Of Counsel network at (888) 437-7747.
What should I bring to an initial consultation about a Peru-connected VASP matter?
For an initial consultation on a cross-border VASP matter, bring a description of the VASP’s business model, the virtual assets involved, the jurisdictions where the VASP has customers or operations, and any existing regulatory registrations or correspondence. Relevant materials may include the entity’s corporate structure, a summary of its token or asset offerings, its customer onboarding and transaction-flow documentation, and any prior legal analyses of the assets’ regulatory classification. If the VASP has already received inquiries from US or Peruvian regulators, those communications are important to review. The consultation will focus on identifying the US regulatory triggers, the Peruvian-law dimensions, and the path forward for compliance and registration. All information shared in the consultation is protected by attorney-client confidentiality. For guidance on your specific cross-border situation, reach Law Offices of SRIS, P.C. at (888) 437-7747.
Does the firm handle VASP registration with FinCEN for Peru-based businesses?
Yes — the US-admitted attorneys at Law Offices of SRIS, P.C. handle FinCEN MSB registration and BSA/AML compliance program development for Peru-based VASPs that have a US nexus requiring registration under the Bank Secrecy Act. The registration analysis begins with a threshold determination of whether the VASP meets the definition of a money services business under 31 C.F.R. § 1010.100(ff). If registration is required, the firm prepares and files the FinCEN Form 107 registration, designs a risk-based AML compliance program meeting the requirements of 31 C.F.R. § 1022.210, and advises on ongoing compliance obligations including suspicious-activity reporting and independent review requirements. The Peru-law side of the entity’s corporate and regulatory structure is handled by Martín Mayandía, Of Counsel, admitted to practice law in Peru (2009) and not admitted in any US state bar. For a consultation on FinCEN registration for your Peru-based VASP, contact Law Offices of SRIS, P.C. at (888) 437-7747.