VASP Licensing and Waiver Application Checklist (New Applicants)

Summary

This is a CIMA checklist form used by new applicants seeking either a Virtual Asset Service Provider (VASP) licence or a waiver from VASP licensing/registration requirements under the Virtual Asset (Service Providers) (Amendment) Regulations, 2025. It sets out, item-by-item, the documents and information that must accompany an application.

• General corporate information
• Business plans
• Financial and capital information
• Governance and risk policies
• AML/CFT/CFP/sanctions compliance frameworks
• Cybersecurity and wallet/private-key management policies
• Outsourcing arrangements
• Fitness-and-propriety documentation for shareholders, directors and senior officers
• Part B: Custodial services
• Other parts: Other VASP-specific activities, location/office details (Part D), and a signed declaration (Part E)

The checklist distinguishes between full licensing applicants, who must respond to and supply documentation for essentially every item, and waiver applicants, who need only complete Part A, Part D and Part E, plus supporting rationale for the waiver. It explains that CIMA will not begin processing or reviewing an application until all required documents have been submitted and verified, meaning incomplete packages will delay review.

The document is purely a procedural/administrative checklist rather than a standalone law or rule, but by cross-referencing the VASP Act, the Rule for Virtual Asset Custodians and Trading Platforms, the Proceeds of Crime Act, and the AML Regulations, it operationalises those underlying substantive requirements for applicants. It applies to any person or entity applying for a new VASP licence or a waiver in the Cayman Islands, including their parent companies, subsidiaries, shareholders, directors and senior officers who must undergo fitness-and-propriety vetting.

Key obligations

• Licensing applicants must provide a response and supporting documentation for every item listed in the checklist (Parts A through E as applicable).
• Waiver applicants must complete and provide supporting documentation only for Part A, Part D and Part E, plus any additional information supporting the waiver rationale.
• Applicants must pay the CI$5,000 application fee for licensing applications (not applicable to waivers).
• Documents submitted must be numbered according to the checklist's item numbering system.
• Non-English documents must be accompanied by notarized or certified English translations.
• Shareholders, directors and senior officers not previously known to the Authority must submit a Personal Questionnaire, Police Clearance Certificate/Affidavit of No Conviction dated within six months of the application date, two character references (minimum 3-year relationship), a financial reference (minimum 2-year relationship), a CV, and notarized ID and qualification copies.
• Previously approved shareholders, directors and senior officers must submit an updated signed Personal Questionnaire, an Affidavit of No Material Changes, and a Police Clearance Certificate/Affidavit of No Conviction dated within six months of the application date.
• Individuals holding more than 10% shareholding must submit a Source of Wealth Form.
• Applicants must submit a signed declaration (Part E) from two senior officers confirming authorisation and accuracy of the application and compliance with the VASP Act and AML Regulations.
• Applicants offering virtual asset custody services must complete Part B, including policies on custody of client assets, concentration risk, insurance, and evidence of professional knowledge and experience of key personnel.
• CIMA will not begin processing or reviewing the application until all required documents have been submitted and verified.

Applies to

Virtual Asset Service Providers (VASPs), Applicants for VASP licence, Applicants for VASP waiver, Virtual asset custodians, Shareholders, directors and senior officers of applicants, Parent and subsidiary entities of applicants

Deadlines

• within six (6) months of application date: Police Clearance Certificate/Affidavit of No Conviction must be dated within six months of the application date for individuals not previously known to the Authority and for previously approved individuals.