Virtual Asset (Service Providers) (Amendment) Act, 2024 (Act 22 of 2024)

Status per the Consolidated Index of Laws and Subsidiary Legislation (as at 2026-02-28)

Summary

This is an amending Act that updates the Virtual Asset (Service Providers) Act (2024 Revision), the core law governing virtual asset businesses in the Cayman Islands. It does not create a new regulatory regime but revises definitions, tightens supervisory and enforcement powers of the Cayman Islands Monetary Authority (CIMA), and clarifies fee arrangements for licensees and registered persons. It applies to virtual asset service providers (VASPs), including registered persons, licensees, applicants for registration or a licence, and "supervised persons" (entities licensed/registered under other CIMA regulatory laws).

Substantively, the amendments introduce several changes to the regulatory framework.

Fee structure overhaul: Application, registration and licence fees are now non-refundable, with a fee due within 30 days of approval notification or the approval lapses.
Fit-and-proper test: Imposed on shareholders, directors and senior officers.
Board composition: Requires at least three directors, including one independent director, for VASPs.
Public statements: Restricts public statements implying a person is licensed or regulated when it is not.
Business plan changes: Requires prior written CIMA approval for changes to an approved business plan or scope of services.
Corporate change notification: Requires notification to CIMA within 30 days of certain corporate changes.
Enforcement powers: Strengthens CIMA's entry, search and seizure powers (replacing section 33) and updates offences/penalties for obstruction.

The Act commences on a date (or dates) to be appointed by Cabinet Order, meaning different provisions may take effect at different times; as of the text provided, no specific commencement date is stated. A transitional provision preserves refundability of fees for applications already pending immediately before commencement, despite the new non-refundable fee rule.

Key obligations

Applicants for registration or a licence must pay the prescribed application fee with their application; these fees are non-refundable except as provided in the transitional clause.
Applicants who are approved must pay the prescribed registration or licence fee within thirty days of being notified of approval, or the approval will be cancelled by the Authority.
A registered person who, at commencement of this amending Act, is engaged in an activity for which a licence is required must apply for a licence within ninety days of commencement.
Persons not registered, licensed or granted a waiver (including applicants) must not state, imply or convey that they are regulated or authorised by the Authority to provide virtual asset service.
Registered persons must not publicly state, imply or convey that they are licensed for virtual asset custodial services, operation of a trading platform, or otherwise licensed under the Act.
Virtual asset service providers must maintain no less than three directors at all times, including at least one independent director without a vested interest in the provider.
Applicants for registration/licence must satisfy the Authority that shareholders, directors, beneficial owners and senior officers are fit and proper persons.
Virtual asset service providers must carry on services only in accordance with their approved application and business plan and must seek prior written Authority approval before changing the approved business plan or adding new virtual asset services.
Virtual asset service providers must notify the Authority within thirty days of specified changes (e.g., establishing a subsidiary, agency, branch or other physical presence, or facing penalties/enforcement actions/litigation).
When performing a virtual asset transfer, providers must collect and maintain originator/beneficiary information per the Anti-Money Laundering Regulations (2023 Revision) and provide such records to the Authority or a competent authority within forty-eight hours of a request.
Fees for applications pending immediately before commencement of this amending Act remain refundable, notwithstanding the new non-refundable fee rule.

Applies to

virtual asset service providers, registered persons, licensees under the Virtual Asset (Service Providers) Act, applicants for registration, waiver or licence, supervised persons (entities licensed/registered under other regulatory laws)

Deadlines

30 days after being notified by the Authority of approval: Applicant must pay the prescribed registration or licence fee, or the approval is cancelled.
90 days after commencement of the Virtual Asset (Service Providers) (Amendment) Act, 2024: A registered person already engaged in an activity requiring a licence at commencement must apply for a licence.
within thirty days: A virtual asset service provider must notify the Authority of specified changes (e.g., new subsidiary, agency, branch or physical presence, penalties, enforcement actions or litigation).
within forty-eight hours of receipt of a request: Records on beneficiary/originator information must be provided to the Authority or a competent authority upon request.
on such date as may be appointed by Order made by the Cabinet: Commencement of the Act (different dates may be appointed for different provisions); no specific date stated in the text.
the day immediately preceding commencement of this amending Act: Transitional rule: fees for applications with a decision pending on this date remain refundable despite the new non-refundable fee provision.

Virtual Asset (Service Providers) (Amendment) Act, 2024 (Act 22 of 2024)

Summary

Key obligations

Applies to

Deadlines

Related documents

Topics

Version history

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