Supervisory Circular - VASP Registration Reminder (2021-01-15)

Summary

This is a short supervisory circular issued by the Cayman Islands Monetary Authority (CIMA) reminding entities that provide or propose to provide virtual asset services of their obligation to register or notify under the Virtual Asset (Service Providers) Act, 2020 (the VASP Act). CIMA had opened its registration/notification process on 31 October 2020, and this circular sets a firm deadline for completing that process.

The circular applies to "New Market Entrants," "Pre-Existing Service Providers," and "Other Authorized Entities" (categories defined in an earlier 30 October 2020 supervisory information circular) that are providing or intend to provide virtual asset services in or from the Cayman Islands. The circular clarifies that the same Registration/Notification Application form serves both registration and notification purposes.

• Required forms via REEFS: Entities must submit two forms via CIMA's REEFS electronic platform: the VASP Registration/Notification Application (APP-101-84) and the AML/CFT Inherent Risks – Virtual Asset Service Provider form (AIR 157-84).
• Deadline: Both forms must be submitted on or before 31 January 2021.
• Consequence of non-compliance: Entities that fail to register or notify by that date will be in breach of the VASP Act as of 1 February 2021 and must cease conducting virtual asset services, with possible enforcement action for failure to do so.

The document is informational/reminder in nature but reiterates a binding statutory deadline already established under the VASP Act.

Key obligations

• Entities providing or proposing to provide virtual asset services must submit the VASP Registration/Notification Application (APP-101-84) via CIMA's REEFS platform.
• Entities providing or proposing to provide virtual asset services must submit the AML/CFT Inherent Risks – Virtual Asset Service Provider Form (AIR 157-84) via CIMA's REEFS platform.
• Both the Registration/Notification Application and the Inherent Risk Form must be submitted on or before 31 January 2021.
• Entities that fail to register or provide notice by 31 January 2021 must cease conducting virtual asset services as of 1 February 2021.

Applies to

New Market Entrants, Pre-Existing Service Providers, Other Authorized Entities, virtual asset service providers

Deadlines

• 31 January 2021: Deadline for submission of the VASP Registration/Notification Application (APP-101-84) and the AML/CFT Inherent Risks – Virtual Asset Service Provider Form (AIR 157-84) via REEFS.
• 1 February 2021: Entities not registered or having provided notice by 31 January 2021 will be in breach of the VASP Act and must cease conducting virtual asset services.