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The Cayman amendment advances Phase Two of the VASP regime by licensing custody and trading-platform services and strengthening governance, ownership, safeguarding and supervisory requirements.
Current state: Phase Two licensing provisions commenced 2025-04-01; check commencement orders for remaining sections
Jurisdiction
Cayman IslandsRegulator
Cayman Islands Monetary Authority
Law Type
Act
Status
Partially EffectiveOfficial Law Number
Act 22 of 2024
Official Title
Virtual Asset (Service Providers) (Amendment) Act, 2024
Effective Date
April 1, 2025
Publication Date
November 11, 2024
Last Verified
August 26, 2026
Cayman VASPs, custodians, trading platforms, exchanges, controllers, directors, auditors, service providers and customers.
CIMA licence for custody and trading-platform services; controller and director approval; governance and audit; client-asset segregation; cyber and operational controls; fees, reporting, inspections and enforcement; registered activities remain subject to AML/CFT.
Authorization rule: CIMA licence for custody and trading-platform services.
AML/CFT duties are material; consult the instrument and current implementing rules for scope, thresholds and filing mechanics.
Customer-asset, segregation, key-security or custody controls are within scope; verify detailed regulator rules.
No dedicated marketing code is the primary focus; ordinary consumer and advertising law may still apply.
Regulator: Cayman Islands Monetary Authority.
Not a tax code. Tax consequences depend on taxpayer, asset and transaction under the jurisdiction's current tax law.
Virtual Asset (Service Providers) Act (2024 Revision)
The Cayman Islands Virtual Asset (Service Providers) Act 2020, as revised in 2024, creates registration and supervisory requirements for virtual-asset service providers operating in or from the Cayman Islands. Phase Two, effective 1 April 2025, introduces full licensing requirements for custody and virtual-asset trading platforms. The canonical profile covers the Act with the linked 2024 amendment and 2025 commencement order.
Decision No. E/35/2023 on Virtual Asset Service Provider Registration, Cancellation of Registration and AML/CFT Instructions
Oman's FSA Decision No. E/35/2023 requires registration with the Oman Financial Services Authority (formerly Capital Market Authority) before carrying on covered virtual-asset activities in the Sultanate of Oman. It implements AML/CFT, governance and compliance requirements, and provides registration, cancellation and supervisory procedures. This is a VASP registration/AML regime and should be distinguished from any future full licensing framework.
Resoluções BCB nos. 519, 520 e 521, de 10 de novembro de 2025
Brazil's Central Bank (BCB) Resolutions No. 519, 520 and 521 of 10 November 2025 implement the virtual-asset regulatory framework under the supervision of the Central Bank. Resolution 519 establishes VASP authorisation procedures; Resolution 520 sets activity, governance, controls, security and conduct requirements; Resolution 521 integrates specified virtual-asset operations into Brazil's foreign-exchange and international-capital rules. Commencement is staged during 2026 — verify the effective date for each resolution separately.
Policy Recommendations for Crypto and Digital Asset Markets — Final Report (FR11/2023)
The IOSCO Policy Recommendations for Crypto and Digital Asset Markets (2023) contain 18 recommendations grounded in the principle of consistent regulation of economically equivalent activities. They address conflicts of interest, market manipulation, custody, disclosure, retail risks and cross-border cooperation. IOSCO recommendations are not self-executing domestic law — implementation depends on member regulators in their respective jurisdictions.
Utility Token Offering Act, 2018 (Act No. 4 of 2018)
Anguilla's Utility Token Offering Act 2018 (Act No. 4/2018) is one of the world's earliest purpose-built utility-token offering frameworks. It creates registration requirements for utility-token issuers, sets offering, disclosure and issuer-qualification conditions, and works with AML regulations and later amendments. Verify the most recent consolidation — a 2020 amendment may affect the effective/status fields.
Resolución SBS N.° 02648-2024 — Normas para la Gestión de Riesgos de LA/FT aplicable a PSAVs
Peru's SBS Resolution No. 02648-2024 applies AML/CFT risk-management and compliance duties to virtual asset service providers (PSAVs) supervised by UIF-Peru. It requires customer due diligence, recordkeeping and suspicious-transaction reporting. The resolution also contains a travel-rule chapter, but commencement of the travel rule has been deferred to 1 January 2029 through a later amendment — the travel rule is not currently effective.
