VASP Registration Reminder (2021-01-15)

Summary

This is a Supervisory Information Circular issued by the Cayman Islands Monetary Authority (CIMA) on 15 January 2021, reminding entities that provide or intend to provide virtual asset services in the Cayman Islands to complete their registration or notification obligations under the Virtual Asset (Service Providers) Act, 2020 (the VASP Act). CIMA had commenced the registration/notification process on 31 October 2020, and this circular sets a firm deadline for New Market Entrants, Pre-Existing Service Providers and Other Authorized Entities to submit the required forms.

• VASP Registration/Notification Application (APP-101-84): Serves both registration and notification purposes; must be submitted through CIMA's REEFS electronic platform on or before 31 January 2021.
• AML/CFT Inherent Risks Virtual Asset Service Provider form (AIR 157-84): Must also be submitted through CIMA's REEFS electronic platform on or before 31 January 2021.

The circular warns that any entity conducting virtual asset services that has not registered or notified CIMA by 31 January 2021 will be in breach of the VASP Act as of 1 February 2021 and must cease conducting virtual asset services. Failure to cease may expose the entity to enforcement measures by CIMA. The circular is purely a reminder of existing statutory obligations and deadlines rather than a new substantive rule.

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 must also submit the AML/CFT Inherent Risks - Virtual Asset Service Provider form (AIR 157-84) via REEFS.
• Both forms must be submitted on or before 31 January 2021.
• Entities that fail to register or notify by 31 January 2021 must cease conducting virtual asset services as of 1 February 2021 to avoid being in breach of the VASP Act.

Applies to

New Market Entrants, Pre-Existing Service Providers, Other Authorized Entities, Virtual Asset Service Providers (VASPs)

Deadlines

• 31 January 2021: Deadline for submitting the Registration/Notification Application (APP-101-84) and the Inherent Risk Form (AIR 157-84) via REEFS.
• 1 February 2021: Entities not registered/notified by this date are in breach of the VASP Act and must cease conducting virtual asset services.