Virtual Asset (Service Providers) Act, 2020 (Commencement) Order, 2025 (SL 18 of 2025)

Summary

This is a Commencement Order made by the Cayman Islands Cabinet that brings specific provisions of the Virtual Asset (Service Providers) Act, 2020 into force on 1 April 2025. The Act itself was passed in 2020, but many of its sections required a separate commencement order before they became legally operative, and this Order identifies exactly which sections (listed in the Schedule) take effect on that date.

The provisions activated relate mainly to the licensing regime for virtual asset service providers.

• Licence applications and grants: Sections 3(1), 5, 8, 10, 11.
• Obligations on licensees: Obligations on existing and new virtual asset service licensees.
• CIMA regulatory powers: Regulatory powers of CIMA over licensees under sections 16, 24, 25, 27, 30-32.
• Former licensees: Provisions applying to former licensees under section 34.
• Other related matters: Sections 4, 9(6), 35(3).
• Exclusions: Some subsections are expressly excluded from commencement (e.g. section 8(2)(b)).

The Order itself does not create new substantive rules; rather it is the legal trigger that makes the listed sections of the Act binding law from 1 April 2025. Anyone providing, or intending to provide, virtual asset services in or from the Cayman Islands, or already holding a licence/registration under the Act, needs to be aware that these licensing and supervisory provisions are now in force and enforceable.

Key obligations

• Virtual asset service providers and applicants must comply with the licensing provisions of the Act (sections 3(1), 4(1)(b)-(c), 5, 8, 10, 11) as they are now in force from 1 April 2025.
• Existing licensees and virtual asset service licensees become subject to the ongoing regulatory obligations under sections 16, 24(1)(c)(iii), 25, 27, 30, 31, 32, and 34 of the Act from the commencement date.
• Persons subject to section 9(6) and 35(3) of the Act must comply with those provisions from 1 April 2025.

Applies to

virtual asset service licensees, existing licensees, applicants for virtual asset service licences, former licensees

Deadlines

• 1st April, 2025: Date on which the specified provisions of the Virtual Asset (Service Providers) Act, 2020 listed in the Schedule come into force.