Standards
VAACA Framework 01 — PSAN Regulatory Readiness
Three perimeter gates decide whether an activity is in scope. Eight readiness domains, scored on a 24-point scale, decide whether it can be presented to a regulator today.
Gate 1
Perimeter Test
Does the applicant's activity fall inside the virtual-asset perimeter at all, or is it already licensed under banking, payments, or securities law?
Gate 2
Requalification Test
Could the activity be requalified as a security, e-money, or payment service under existing law — bypassing the PSAN category entirely?
Gate 3
Regulator Test
Which body has actual jurisdiction today — COBAC, COSUMAF, or a future CEMAC-level virtual-asset authority — and is that body currently equipped to receive an application?
D1
Governance
Board/management structure, fit-and-proper controls, documented decision rights.
D2
AML/CFT
Customer due diligence, transaction monitoring, suspicious-activity reporting to ANIF.
D3
Custody & Security
Key management, cold/hot wallet segregation, incident response.