Cayman Islands updates virtual asset regulations: Key changes effective April 2025
Highlights of the amendments
Mandatory licensing – VASPs offering virtual asset custody or trading platform services will now require a licence. This marks a transition from mere registration to more stringent licensing requirements.
Updated definitions and governance – The amendments redefine key terms and introduce enhanced prudential standards. Affected providers must have at least three directors and pay non-refundable fees as part of the licensing process.
Licensing process for existing and new providers
- Existing registered providers
VASPs currently registered under the law but engaged in licensable activities must apply for a license within 90 days of the commencement date. They must submit required documentation per the updated regulations, and transition checklists have been made available for guidance. - New applicants
New VASPs intending to offer custody or trading services after 1 April 2025 must apply through CIMA’s online platform, including all documentation outlined in the updated regulations.
Waivers for certain supervised persons – Entities already licensed under other regulatory laws may apply for a waiver if their virtual asset services do not materially alter the scope of their current regulated activities. A legal opinion and supporting documents are required to secure the waiver.
Application fees and compliance
Applicants must pay fees for both application submissions and license issuance, as outlined in the amended regulations. Entities failing to comply or engaging in unlicensed activities post implementation will face enforcement measures, including penalties and cessation orders.
Next steps
CIMA will provide further guidance over the coming months to support a smooth transition for existing and new VASPs. Entities are encouraged to review relevant policies, schedule consultations with CIMA, and ensure compliance to avoid penalties.
For more information, CIMA’s press release can be found here and the FAQs page can be accessed here.