Virtual Asset (Service Providers) (Amendment) Regulations, 2025 (SL 19 of 2025)

Summary

This is an amendment to the Virtual Asset (Service Providers) Regulations, 2020, made under the Virtual Asset (Service Providers) Act (2024 Revision). It introduces a new regulation 4A requiring that applications for a virtual asset service licence under section 8(1) of the Act be submitted to the Cayman Islands Monetary Authority (CIMA) using a newly prescribed application form, set out as new Schedule 1A. It also repeals and replaces the fee schedule (Schedule 2) governing registration and licence fees payable under the Act.

New Schedule 1A Application Form

The new Schedule 1A form requires applicants to provide detailed information depending on the type of virtual asset service they intend to provide.

• All applicants: Must supply general business information (activities, financial projections, management structure, customer base, and financial statements), plus ownership and capital structure details, auditor information, and any requested exemptions.
• Virtual asset custody service applicants: Must additionally address custody arrangements, cybersecurity and risk management measures, AML/CFT compliance strategy, client agreements, insurance, and outsourcing arrangements.
• Virtual asset trading platform applicants: Must address platform governance, listed assets, client agreements, conflicts of interest, clearing and settlement processes, and related AML/CFT and operational safeguards.
• Declaration: The form ends with a declaration to be signed by two senior officers confirming accuracy of the information and compliance with the Act, the Regulations, and Anti-Money Laundering Regulations.

New Schedule 2 Fees

The amendment also substitutes a new Schedule 2 setting out revised registration and licence fees (in Cayman Islands dollars), varying by category of virtual asset service (issuance, custody, or trading platform operation), by projected or actual revenue thresholds, and by whether the applicant or licensee is a 'local company' as defined under the Local Companies (Control) Act (2025 Revision), which benefits from substantially reduced fees. The Regulations come into force immediately after the Virtual Asset (Service Providers) (Amendment) Act, 2024 comes into force.

Key obligations

• Applicants for a virtual asset service licence under section 8(1) of the Virtual Asset (Service Providers) Act must submit their application to the Authority using the form set out in new Schedule 1A.
• Licence applicants must submit the Schedule 1A form together with completed paragraphs A and B of the Application for Registration form (unless already registered under the Act) and any additional information required by the Authority.
• Applicants for virtual asset custody services must complete Part B of Schedule 1A, covering custody arrangements, cybersecurity/risk management strategy, AML/CFT/proliferation financing risk mitigation strategy, client agreements/disclosures, insurance details, outsourcing contracts, and evidence of professional knowledge/experience including named qualified directors.
• Applicants for operation of a virtual asset trading platform must complete Part C of Schedule 1A, covering platform revenue, hardware location, standard client agreements, governance structure, listed assets, conflicts-of-interest measures, AML/CFT due diligence, outsourcing agreements, and evidence of qualified directors.
• The application must include a declaration signed by two senior officers of the applicant confirming authorisation, understanding of the Act, Regulations, and Anti-Money Laundering Regulations (2025 Revision), and accuracy of the information provided.
• Registered persons and licensees must pay the registration, licence application, grant, and annual renewal fees set out in the new Schedule 2, calculated according to the applicable category, revenue thresholds, and whether the entity qualifies as a local company.

Applies to

virtual asset service providers, virtual asset custodians, virtual asset trading platform operators, applicants for virtual asset service licence or registration, registered persons under the Virtual Asset (Service Providers) Act

Deadlines

• immediately after the Virtual Asset (Service Providers) (Amendment) Act, 2024 comes into force: Commencement date of these Regulations

Related documents

• This document is made under Virtual Asset (Service Providers) Act (2024 Revision)
• This document amends Virtual Asset (Service Providers) Regulations, 2020 (SL 138 of 2020)