Virtual Asset Service Provider Licence (Cayman Islands)
The Virtual Asset Service Provider Licence (custody or trading platform services, Phase 2) is issued by Cayman Islands Monetary Authority (CIMA) under Virtual Asset (Service Providers) Act (2024 Revision). The application fee is KYD 5,000. Ownership changes need the regulator's approval before completion.
At a glance
| Official name | Virtual Asset Service Provider Licence1 |
|---|---|
| Local name | custody or trading platform services, Phase 2 |
| Also known as | CIMA VASP licence · Cayman virtual asset licence · Phase 2 VASP licence · Cayman crypto custody licence · Cayman crypto trading platform licence · VASP licence |
| Issued by | Cayman Islands Monetary Authority |
| Jurisdiction | Cayman Islands |
| Licence family | Virtual asset service provider (non-MiCA) |
| Legal basis | Virtual Asset (Service Providers) Act (2024 Revision)2 |
| Passporting | Domestic only |
| Application fee | KYD 5,0003 |
What it lets you do, and where
What does a Cayman VASP Licence let you do, and where can you serve clients?
Sections 10 and 11 of the Virtual Asset (Service Providers) Act establish statutory requirements for virtual asset custody services and virtual asset trading platforms. Custody means safekeeping or administration of virtual assets, while trading platforms facilitate exchange while holding custodial control. For EU retail passporting, no offshore structure substitutes for a MiCA CASP authorization.2713
Activities it covers
| Custody and administration of crypto-assets | Safekeeping or controlling crypto-assets, or the means of access to them such as private keys, on behalf of clients. |
|---|
Where it is valid
Do you need it, and is Cayman Islands the right choice?
What is a Cayman Islands VASP Licence and do you actually need one?
A Cayman Islands VASP Licence is an authorisation issued by CIMA under the Virtual Asset (Service Providers) Act (2024 Revision). Section 4 requires registration or a licence, with a licence needed for custody services or operating a trading platform; Section 8 governs the application. Phase Two commenced on 1 April 2025, requiring all custody and trading platform providers to obtain a licence. The VASP Law applies to all entities that intend to or currently provide virtual asset services in or from within the Cayman Islands.271
Is a Cayman VASP Licence right for your model, and when is Cayman the wrong choice?
A Cayman VASP licence suits firms that want a FATF-aligned jurisdiction and can support its governance load. Since Phase Two, a licensee needs at least three directors, including an independent director, and a full compliance set-up. It is the wrong choice if you need EU retail passporting, for which a MiCA CASP authorisation is required.121415
Is a Cayman Islands VASP licence real regulation or just company registration?
Yes, it is real regulation. From 1 April 2025 a CIMA Supervisory Circular established a full licensing regime with enhanced prudential and governance standards. All virtual asset service licensees must have annual accounts audited by a CIMA-approved independent auditor (Section 31). CIMA enforces the regime: it cancelled AC Holding Limited's registration on 5 June 2025 for compliance, AML and governance failures.2157
Can you serve EU or US clients with a Cayman VASP licence?
For EU retail passporting, no offshore structure substitutes for a MiCA CASP authorization. CIMA VASP Regulatory Policy Section 7.8.3(n) requires applicants to submit an attestation of jurisdictions where they operate and confirm compliance with all local laws. Section 9(4)(c) of the Virtual Asset (Service Providers) Act requires licensees to notify CIMA of any licence, registration, or enforcement action in another jurisdiction.13122
How do you check if a Cayman VASP licence is legitimate and spot fake or clone entities?
Use the CIMA Search Entities portal to look up an entity's reference number, legal name, licence or registration type, and active status. The CIMA Warning Notices page publishes official enforcement notices against non-compliant entities and directors in potential breach of regulatory laws. Sections 4(1)-(3) and 35 of the Virtual Asset (Service Providers) Act make it an offence to carry on or purport to carry on virtual asset service without authorization.16172
What it really takes
How much capital do you really need for a Cayman VASP Licence?
Sections 8(4)(b)(iii) and 22(h) of the Virtual Asset (Service Providers) Act require adequate capital and net worth assessed according to business size, scope, and complexity. Section 10(1)(d) empowers the Authority to impose requirements for the safekeeping of client assets, including the segregation of assets. KPMG notes that VASPs must segregate client assets from proprietary assets to enhance consumer protection under Phase Two.214
Who do you have to hire for a Cayman VASP and where must they be based?
The CIMA Supervisory Circular confirms amendments to the VASP Act include enhanced prudential requirements and a requirement for at least three directors. Section 9(8) of the Virtual Asset (Service Providers) Act prohibits appointing senior officers, trustees, or an AML compliance officer without CIMA's prior approval. CIMA VASP Regulatory Policy Section 7.9.5 mandates that the MLRO and AMLCO possess specific AML/KYC knowledge relating to the Cayman Islands regulatory framework.7212
The legal framework
| Level | Document | What it does here |
|---|---|---|
| Act | Virtual Asset (Service Providers) Act (2024 Revision) | Primary statute governing the registration and licensing of virtual asset service providers, establishing the requirement for a virtual asset service licence for custody and trading platforms (s. 4, 8), statutory duties (s. 9-11), assessment criteria (s. 22), supervisory and enforcement powers (s. 24-27), 10% change-of-control prior approval (s. 28), and statutory right of appeal to the Grand Court (s. 30) |
| Act | Virtual Asset (Service Providers) (Amendment) Act, 2024 (Act 22 of 2024) | Amending act enhancing the supervisory framework, governance standards, and transitional provisions for Phase 2 licensing of virtual asset custodians and trading platform operators |
| Act | Monetary Authority Act (2020 Revision) | Constitutive statute establishing CIMA, defining its regulatory and supervisory powers over financial services, rule-making authority (s. 34), and empowering CIMA to issue regulatory policies, procedures, and rules |
| Act | Companies Act (2023 Revision) | Provides the corporate law foundation for Cayman Islands companies, corporate capacity, director duties, share issuance and transfer, and register of members |
| Secondary legislation | Virtual Asset (Service Providers) Act, 2020 (Commencement) Order, 2025 (SL 18 of 2025) | Commencement order bringing Phase 2 of the VASP Act (mandatory licensing for virtual asset custody services and trading platforms under sections 4(1)(b) and 8) into legal force on 1 April 2025 |
| Secondary legislation | Virtual Asset (Service Providers) Regulations, 2020 (SL 138 of 2020, as amended by SL 19 of 2025) | Principal secondary legislation implementing the VASP Act, prescribing registration and licensing procedures, information schedules, and operational standards |
| Secondary legislation | Virtual Asset (Service Providers) (Amendment) Regulations, 2025 (SL 19 of 2025) | Implements Phase 2 licensing by inserting Regulation 4A, Schedule 1A (mandatory Licence Application Form for custody and trading platforms), and substituting Schedule 2 (Fee Schedule) |
| Regulator rules | Regulatory Policy: Registration or Licensing of Virtual Asset Service Providers (updated May 2025) | CIMA regulatory policy governing assessment criteria for VASP registration and licensing, fit and proper assessments, business plan requirements, 3-director governance mandate, and procedural evaluation rules |
| Regulator rules | Regulatory Policy: Criteria for Approving Changes in Ownership and Control | Specifies CIMA's criteria and documentation requirements for approving 10% or greater changes in ownership or control of regulated entities under Section 28 of the VASP Act |
| Regulator rules | Rule and Statement of Guidance: Market Conduct for Virtual Asset Service Providers | Mandatory market conduct rules for VASPs regarding client asset segregation, transparent pricing, conflict-of-interest management, handling of complaints, disclosures, and fair dealing |
| Regulator rules | Rule and Statement of Guidance: Corporate Governance for Regulated Entities | Establishes mandatory corporate governance standards, board composition, oversight responsibilities, and management accountability for CIMA-regulated entities |
| Regulator rules | Rule and Statement of Guidance: Internal Controls for Regulated Entities | Sets binding rules for internal control frameworks, risk management, accounting systems, and independent internal audit functions across regulated entities |
| Regulator rules | Rule and Statement of Guidance: Cybersecurity for Regulated Entities | Prescribes comprehensive cybersecurity governance, risk management frameworks, data and key protection, threat monitoring, incident reporting within 72 hours, and periodic independent penetration testing |
| Regulator rules | CIMA Regulatory Policy: Fitness and Propriety (December 2020) | Sets CIMA's standards and verification procedures for assessing the honesty, integrity, competence, capability, and financial soundness of directors, senior officers, and beneficial owners |
| Procedure law | Grand Court Act (2015 Revision) and Grand Court Rules (1995 Revision as amended) | Regulates judicial proceedings, procedure on originating motions, and appeals from administrative and statutory bodies to the Grand Court of the Cayman Islands under Section 30 of the VASP Act |
| Fee schedule | Schedule 2 to the Virtual Asset (Service Providers) Regulations, 2020 (as substituted by SL 19 of 2025) | Prescribes the statutory non-refundable application fee (KYD 5,000), licence grant fees (KYD 30,000 for custody; KYD 100,000 for trading platform), and tiered annual renewal fees (KYD 30,000-120,000 for custody; KYD 50,000-200,000 for trading platforms) |
| Forms | REEFS Form APP-101-84-05, Form AIR-157-84, and Personal Questionnaire Form APP-101-76 | Mandatory electronic application forms in CIMA's REEFS portal incorporating Schedule 1A data requirements, accompanied by Form AIR-157-84 (AML/CFT Inherent Risk Return) and Form APP-101-76 (Personal Questionnaire) |
6 related regimes and guidance documents
| Level | Document | What it does here |
|---|---|---|
| Guidance | Statement of Guidance: Outsourcing for Regulated Entities | Guidance on assessing risks, due diligence, contractual protections, and supervisory access when outsourcing material operational or business functions to third parties or group affiliates |
| Guidance | Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the Cayman Islands (specifically Part VI - Virtual Asset Service Providers) | Comprehensive supervisory guidance on customer identification and verification, transaction monitoring, AMLCO/MLRO appointments, and implementation of the FATF Travel Rule for virtual asset transfers |
| Related regime | Proceeds of Crime Act (2024 Revision) | Principal criminal AML statute criminalising money laundering, terrorist financing, and proliferation financing, defining reporting obligations, and empowering the Financial Reporting Authority (FRA) to receive suspicious activity reports (SARs) from VASPs |
| Related regime | Anti-Money Laundering Regulations (2025 Revision) | Sets binding AML/CFT/CPF standards for financial services providers, including mandatory customer due diligence (CDD), ongoing monitoring, internal compliance officers (AMLCO/MLRO), and the FATF Travel Rule for virtual asset transfers under Part XA |
| Related regime | Securities Investment Business Act (2020 Revision) | Regulates securities investment business in the Cayman Islands; sets the regulatory perimeter where virtual assets constitute securities and governs dual licensing and approval requirements for trading platforms under VASP Act s. 11(4)-(7) |
| Related regime | Beneficial Ownership Transparency Act, 2023 (Act 13 of 2023) | Mandates maintenance and reporting of beneficial ownership registers for Cayman entities, establishing the 25% ownership threshold for UBO reporting alongside the VASP Act's 10% change-of-control threshold |
The procedure under the law
| Step | What the law says | Legal reference |
|---|---|---|
| How to file | New VASP licence applications must be submitted through CIMA's Regulatory Enhanced Electronic Forms Submission (REEFS) online platform. The application is made in the form set out in Schedule 1A of the Virtual Asset (Service Providers) Regulations, 2020 (inserted by SL 19 of 2025), under regulation 4A, which requires an application for a licence under section 8(1) of the VASP Act to be made to the Authority in that form. Supporting documents listed in Schedule 1A and the AML/CFT form must accompany the submission.5678 | Virtual Asset (Service Providers) Act (2024 Revision), s. 8(1), (3); Virtual Asset (Service Providers) Regulations, 2020 (as amended by SL 19 of 2025), reg. 4A and Schedule 1A; CIMA Regulatory Policy on Registration or Licensing of Virtual Asset Service Providers, s. 6.2 |
| Language | No passage states a general filing language for the application or correspondence, any client-facing document language rule, or detailed translation-certification requirements such as translator credentials, a Certificate of Accuracy, or authentication under official seal.1 | |
| What the application contains | The application is made through CIMA's REEFS portal using Form APP-101-84 (with AIR-157-84) and must include a blockchain address list, shareholder details (10%+) with completed personal questionnaires, CIO/CISO information and CV, cybersecurity and AML/CFT policies, a business plan, transaction flow charts, outsourcing details, and fees. For major shareholders, directors and officers, certified qualifications, police clearance, character and financial references, CV, photo ID and source of funds/wealth declarations are required.9618 | Virtual Asset (Service Providers) Act (2024 Revision), s. 8, s. 9, s. 10, s. 11, and s. 22; Virtual Asset (Service Providers) Regulations, 2020 (as amended by SL 19 of 2025), reg. 4A and Schedule 1A (Parts A, B, C, and D); CIMA Regulatory Policy on Registration or Licensing of Virtual Asset Service Providers (May 2025), s. 6-7 |
| Decision clock | No statutory decision deadline applies. The review process only starts when CIMA has a complete application with all required information and supporting documentation (Policy s. 6.10); incomplete applications may be returned (s. 6.12). Applications are decided by CIMA's Management Committee, which generally meets weekly; once approved, an approval notification letter issues in about 2-3 business days (s. 6.14). Silence does not grant approval; unlicensed operation breaches the VASP Act.101 | |
| Fees set by law | Fees are set by the Virtual Asset (Service Providers) (Amendment) Regulations, 2025 (SL 19 of 2025), regulation 5 and Schedule 2. Grant fees are KYD 30,000 (custody only) or KYD 100,000 (trading platform), reduced to KYD 3,000 and KYD 10,000 for local companies under the Local Companies (Control) Act. Renewal fees range from KYD 30,000 to KYD 120,000 (custody) and KYD 50,000 to KYD 200,000 (trading platform), by prior-year revenue.8 | Virtual Asset (Service Providers) Act (2024 Revision), s. 5; Virtual Asset (Service Providers) Regulations, 2020 (as amended by Virtual Asset (Service Providers) (Amendment) Regulations, 2025, SL 19 of 2025), reg. 5 and Schedule 2 Part 2; and CIMA Fee Schedule |
| Grounds for refusal | Section 8(4) of the VASP Act lists the grounds: approval against the public interest; beneficial owners and senior officers not fit and proper; lack of skilled personnel, facilities, books/records/accounting systems, or adequate capital and cybersecurity measures; and non-compliance with other requirements of the Act. Section 22 lists factors the Authority considers when deciding to grant a licence, including AML procedures, internal safeguards, risks to clients and the financial system, and net worth. Incomplete applications may be rejected or returned.102 | |
| Appeal | Yes. Under the Virtual Asset (Service Providers) Act (2024 Revision), s. 30, an appeal lies to the court from CIMA's refusal to grant a licence. It is brought by way of motion: within 21 days after the decision, the appellant must serve a signed notice of motion on CIMA stating the general ground of appeal. The court may extend this time on application. The appeal does not suspend CIMA's decision. At the hearing the appellant must state all grounds relied on; new grounds need leave. The court may confirm, reverse, vary or modify the decision, or remit it to CIMA with its opinion.2 | Virtual Asset (Service Providers) Act (2024 Revision), s. 30: An appeal lies to the Grand Court by way of motion from a decision of CIMA refusing to grant a licence, revoking a licence, taking enforcement action under s. 25, or refusing a virtual asset issuance. The appellant must serve a notice of motion signed by the appellant or attorney-at-law on CIMA within 21 days after the day on which CIMA gave its decision, stating the general ground of appeal (s. 30(2)-(3)). The court may extend the time upon application (s. 30(4)). Upon hearing the appeal, the Grand Court may confirm, vary, or reverse CIMA's decision or remit the matter back to CIMA with directions (s. 30(6)). |
| Validity | Renewal is annual: the prescribed renewal fee must be paid on or before 15 January each year, with a surcharge of one-twelfth of the fee for each month or part month of delay. Unpaid for three full months after 15 January, the licence lapses immediately; within one month the former licensee may pay the fee, surcharges and a ten per cent administration fee to renew for 1 January, 31 December of that year.2 | |
| Change of control | Prior approval from CIMA is required for a change of control or share transfer, except where the shares or interests are listed and traded on a stock exchange approved by the Authority; those are exempt from prior approval, but the FSP must notify CIMA in a timely manner if it relies on the exemption. The process can take several weeks from receipt of a complete application, and changes to application information are assessed within 15 days.1110 | |
| Reapplying after a refusal | None of the governing texts held for this licence (Virtual Asset (Service Providers) Act (2024 Revision); Virtual Asset (Service Providers) Act (2024 Revision); Banks and Trust Companies Act (2025 Revision); Securities Investment Business Act (2020 Revision), Cayman Islands (published as a Law; Cayman statutes are now styled Acts); Mutual Funds Act (2025 Revision); Private Funds Act (2025 Revision); Securities Investment Business Act (2020 Revision), Cayman Islands (published as a Law; Cayman statutes are now styled Acts); Anti-Money Laundering Regulations) contains a provision on a waiting period before a new application after refusal or withdrawal. | |
| Serving other countries | The licence covers virtual asset custody services or operating a virtual asset trading platform in or from within the Cayman Islands (VASP Act s. 8(1)(a); CIMA Policy s. 2.1.2). The Travel Rule in Part XA of the AML Regulations applies to transfers between VASPs and other obliged or non-obliged entities. Foreign-jurisdiction licensing duties are not addressed.1221 |
How long it takes
How long does it really take to get a Cayman VASP Licence?
The VASP Act sets no statutory deadline for CIMA to decide a licence application. Processing starts only after all documents and application fees have been submitted through REEFS. For scale, CIMA's desk reviews and assessments of 11 VASPs ran from September 2024 to February 2025.10115
Section 8 of the Virtual Asset (Service Providers) Act sets no statutory timeline or deemed-approval period for licensing applications. CIMA views an application as complete and ready for processing only after all documentation and fee payments are submitted. Under CIMA's VASP Regulatory Policy, review commences only on a complete application, and CIMA may request additional information during the process.112
What it costs
What does a Cayman VASP Licence cost in total?
CIMA's VASP FAQ sets an assessment fee of CI$1,000 (US$1,219.50), payable through the REEFS portal at application submission. KPMG reports an application fee of KYD 5,000 for a virtual asset service licence. The CIMA Supervisory Circular states that fees under Schedule 2 cover application fees and fees for granting a VASP licence, including for local companies.137
Approval odds and who can own it
What are the real approval odds for a Cayman VASP Licence, and why do applications fail?
CIMA statistics show 18 registered VASPs in Q4 2025; 7 offered custody services and 3 ran trading platforms. Loeb Smith counts 19 registered as of 4 February 2026. CIMA's desk review of 11 VASPs found that 82% had no cybersecurity insurance and 40% had inadequate custody policies. CIMA cancelled AC Holding Limited's registration on 5 June 2025 over documentation, AML and governance failures.1815
Under Section 38 of the VASP Act, beneficial owners, directors and senior officers must be fit and proper persons, judged on honesty, integrity, reputation, competence and financial soundness. Under Section 28(1), CIMA must give prior approval before shares totalling 10% or more are issued or transferred. CIMA's policy requires UBO structure charts and Personal Questionnaires for every beneficial owner of 10% or more.212
Is CIMA actually issuing VASP licences, and how many firms hold one?
Yes. CIMA's official statistics record 18 registered VASPs as of Q4 2025, including 7 custody providers and 3 trading platforms. Loeb Smith reports 19 VASPs registered as of 4 February 2026, after Phase 2 licensing began. CIMA's public search lists currently licensed and registered entities by sector, covering both VASP Licence and VASP Registration.181516
After you get the licence
You will need Travel Rule compliance under Part XA of the Anti-Money Laundering Regulations, effective 1 July 2022. You must also meet the Beneficial Ownership and Transparency Act for all ultimate beneficial owners. Under VASP Act section 9(6), a VASP cannot conduct securities investment business unless registered, licensed or exempted under SIBA, and section 11(4) requires trading platforms to get prior CIMA approval first.1122
Will you get a bank account and payment processing with a Cayman VASP licence?
No. Nothing in CIMA's published VASP material says a licence comes with a bank account or payment processing. Its VASP FAQ only covers how fees reach the Authority: by online bank transfer, wire transfer, cheque or bank draft from a local commercial bank. CIMA Regulatory Policy Section 7.9.8 requires VASPs to demonstrate secure storage and accessibility of financial and accounting books and records.112
Keeping the licence means paying the annual renewal fee by 15 January (Section 5(5)), filing audited accounts within six months of year-end (Section 31), submitting annual AML returns and quarterly Travel Rule returns, and keeping at least three directors. Buying an existing licensee needs CIMA's prior approval under Section 28(1). Phase 2 also brings ongoing supervisory rules and guidance for custodians and trading platforms.2157
Yes. Under Section 30(1) of the Virtual Asset (Service Providers) Act, an appeal lies to the court against a decision of the Authority refusing or revoking a licence. Section 30(3) requires a notice of motion to be served within 21 days, and Section 30(8) provides that an appeal does not suspend execution of the decision.2
The licence is renewed annually: the renewal fee is due 15 January each year, and the licence lapses immediately if it is unpaid for three full months (Section 5(5)-(6)). Prior CIMA approval is needed for senior officers and AMLCOs (Section 9(8)), securities-related virtual asset business (Section 11(4)), and share issues or transfers of 10% or more (Section 28(1)).2
Is the Cayman Islands on the FATF grey list and what does that do to banking?
No. The Cayman Islands Government confirms the FATF plenary decision of October 2023 removing the Cayman Islands from the anti-money laundering grey list. Loeb Smith reports the Cayman Islands VASP Act was introduced to align with FATF standards, which it says makes Cayman a credible, transparent jurisdiction.1915
Buying a company that already holds it
Prior approval required. Under s.28(1) of the VASP Act, CIMA's prior approval is required before any issue or voluntary transfer of shares/interests reaching 10% or more of a VASP; the acquirer must file a Personal Questionnaire and fitness documentation. Acting without approval is an offence, and CIMA may also take action against the licence. Other CIMA-regulated entities (banks, trust companies, mutual fund administrators, securities licensees) face a stricter 0% threshold: any transfer needs prior approval.4
Ready-made companies holding this licence: see verified positions.
VASP in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Abu Dhabi Global Market (ADGM) | VASP licenceFinancial Services Permission with Virtual Asset Activities Endorsement | FSRA | USD 250,000 | USD 20,000 | n/a |
| Australia | VASP licenceRegistration as a virtual asset service provider (VASP) on the AUSTRAC Virtual Asset Service Provider Register (formerly the Digital Currency Exchange Register) | AUSTRAC | n/a | n/a | n/a |
| Bermuda | Digital Asset Business Class F (Full) Licence | BMA | n/a | n/a | n/a |
| Bermuda | Digital Asset Business Class M (Modified) Licence | BMA | n/a | n/a | n/a |
| Bermuda | Digital Asset Business Class T (Test) Licence | BMA | n/a | n/a | n/a |
| British Virgin Islands | Virtual Assets Service Provider Registration | BVI FSC | n/a | n/a | n/a |
| Cayman Islands | Virtual Asset Service Provider Licence | CIMA | n/a | KYD 5,000 | n/a |
| Cayman Islands | Virtual Asset Service Provider Registration | CIMA | n/a | KYD 1,000 | n/a |
| Dubai (VARA) | Virtual Asset Advisory Services Licence | VARA | AED 100,000 | AED 40,000 | n/a |
| Dubai (VARA) | Virtual Asset Broker-Dealer Services Licence | VARA | AED 600,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Custody Services Licence | VARA | AED 600,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Exchange Services Licence | VARA | AED 1,500,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Lending and Borrowing Services Licence | VARA | AED 500,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Management and Investment Services Licence | VARA | AED 500,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Transfer and Settlement Services Licence | VARA | AED 500,000 | AED 40,000 | n/a |
| Dubai International Financial Centre (DIFC) | Financial Services Permission with Crypto Token Activities Endorsement | DFSA | USD 1,000,000 | USD 15,000 | n/a |
| El Salvador | Proveedor de Servicios de Activos Digitales (PSAD) registration | CNAD | USD 2,000 | USD 5,475 | ~0.9 mo |
| Germany | Qualified crypto custody licence | BaFin | n/a | n/a | n/a |
| Ireland | Virtual Asset Service Provider AML/CFT Registration | CBI | n/a | n/a | n/a |
| Mauritius | Virtual Asset Advisory Services (Class I) | FSC | n/a | n/a | n/a |
| Mauritius | Virtual Asset Broker-Dealer (Class M) | FSC | n/a | MUR 2,000,000 | n/a |
| Mauritius | Virtual Asset Wallet Services (Class O) | FSC | n/a | n/a | n/a |
| Mauritius | Virtual Asset Custodian (Class R) | FSC | n/a | MUR 5,000,000 | n/a |
| Mauritius | Virtual Asset Market Place (Class S) | FSC | n/a | MUR 6,500,000 | n/a |
| Seychelles | Virtual Asset Service Provider Licence / RegistrationVirtual Asset Service Provider Licence / Registration (Wallet Provider, Exchange, Broking, Investment Provider) under the Virtual Asset Service Providers Act 2024 | FSA | n/a | SCR 75,000 | n/a |
| South Africa | Crypto Asset Service Provider licenceCrypto Asset Service Provider licence (an FSP authorisation category under FAIS, not a MiCA-equivalent regime) | FSCA | n/a | n/a | n/a |
| Switzerland | Financial intermediary / VASP SRO affiliation | FINMA | CHF 10,000,000 | CHF 1,600 | n/a |
| United Kingdom | Cryptoasset Business Registration (MLRs 2017) | FCA | n/a | GBP 11,260 | ~3 mo |
Values come from each licence's page, where every figure has its source.
Laws behind it
- Virtual Asset (Service Providers) Act (2024 Revision): Law 14 of 2020 (2024 Revision)
Frequently asked questions
What is a Cayman Islands VASP Licence and do you actually need one?
A Cayman Islands VASP Licence is an authorisation issued by CIMA under the Virtual Asset (Service Providers) Act (2024 Revision).
How much capital do you really need for a Cayman VASP Licence?
Sections 8(4)(b)(iii) and 22(h) of the Virtual Asset (Service Providers) Act require adequate capital and net worth assessed according to business size, scope, and complexity.
How long does it really take to get a Cayman VASP Licence?
The VASP Act sets no statutory deadline for CIMA to decide a licence application.
What does a Cayman VASP Licence cost in total?
CIMA's VASP FAQ sets an assessment fee of CI$1,000 (US$1,219.50), payable through the REEFS portal at application submission.
What are the real approval odds for a Cayman VASP Licence, and why do applications fail?
CIMA statistics show 18 registered VASPs in Q4 2025; 7 offered custody services and 3 ran trading platforms.
What does a Cayman VASP Licence let you do, and where can you serve clients?
Sections 10 and 11 of the Virtual Asset (Service Providers) Act establish statutory requirements for virtual asset custody services and virtual asset trading platforms.
Will you get a bank account and payment processing with a Cayman VASP licence?
No. Nothing in CIMA's published VASP material says a licence comes with a bank account or payment processing.
Who do you have to hire for a Cayman VASP and where must they be based?
The CIMA Supervisory Circular confirms amendments to the VASP Act include enhanced prudential requirements and a requirement for at least three directors.
Is a Cayman VASP Licence right for your model, and when is Cayman the wrong choice?
A Cayman VASP licence suits firms that want a FATF-aligned jurisdiction and can support its governance load.
Is a Cayman Islands VASP licence real regulation or just company registration?
Yes, it is real regulation. From 1 April 2025 a CIMA Supervisory Circular established a full licensing regime with enhanced prudential and governance standards. All virtual asset service licensees must have annual accounts audited by a CIMA-approved independent auditor (Section 31). CIMA enforces the regime: it cancelled AC Holding Limited's registration on 5 June 2025 for compliance, AML and governance failures.
Sources
- cima.ky: vasp faq · retrieved 2026-09-24
- Virtual Asset (Service Providers) Act (2024 Revision) · retrieved 2026-09-24
- kpmg.com: vasps · secondary · retrieved 2026-09-24
- maples.com: cima change of control process a guide for cayman islands re · secondary · retrieved 2026-09-24
- cima.ky: virtual asset service providers and · retrieved 2026-10-01
- reefs.cimaconnect.com · retrieved 2026-10-01
- cima.ky: amendments to the virtual asset service providers act effect · retrieved 2026-10-01
- cima.ky: VirtualAssetServiceProvidersAmendmentRegulations2025 1743360 (PDF) · retrieved 2026-10-01
- cima.ky: virtual asset service providers regulatory measures and · retrieved 2026-10-01
- cima.ky: RPy RegistrationorLicensingofVASPs 27 May 25 1748960021 (PDF) · retrieved 2026-10-01
- cima.ky: RegulatoryPolicyonCriteriaforApprovingChangesinOwnershipandC (PDF) · retrieved 2026-10-01
- cima.ky: RegulatoryPolicy RegistrationorLicensingofVASPs 1716492494 (PDF) · retrieved 2026-10-01
- zitadelleag.com: cayman vasp · secondary · retrieved 2026
- kpmg.com: vasps · secondary · retrieved 2025-04-22
- loebsmith.com: cayman islands cimas review of vasps · secondary · retrieved 2026-02-09
- cima.ky: search entities cima · retrieved 2026-09-24
- cima.ky: warning notices · retrieved 2026
- cima.ky: vasp statistics · secondary · retrieved 2026-09-24
- gov.ky: grit commitment gets the cayman islands off fatf list · secondary · retrieved 2023-10-27
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