Cayman Islands
Cayman IslandsCayman has licensed crypto custodians and trading platforms since April 2025 and is a common home for token foundations and crypto funds.
Licences
What it takes to operate in the Cayman Islands: 4 licences, who issues each, what it covers and who holds one.
VASP registration
CIMA · Virtual Asset (Service Providers) Act, sections 4(1)(a) and 6
Virtual asset issuance to the public, exchange between virtual assets and fiat or other virtual assets, transfers, and financial services related to an issuance or sale, where no licence is required.
What it takes
- A Cayman company, partnership, LLC or LLP, or a registered foreign company; natural persons may not provide virtual asset services
- At least three directors, including one independent director, and CIMA approval before appointing senior officers
- Fit and proper beneficial owners of 10% or more and senior officers
- AML/CFT programme and travel rule compliance under Part 10A of the Anti-Money Laundering Regulations
- KYD 1,000 application fee, then a registration fee of KYD 1,500 to KYD 15,000 depending on revenue and where clients are
- Business plan, cybersecurity policies and CIMA's prior approval for new services or changes to the business plan
Virtual asset service licence (custody and trading platforms)
CIMA · Virtual Asset (Service Providers) Act, sections 4(1)(b), 8, 10 and 11, in force since 1 April 2025
Virtual asset custody, meaning safekeeping or administration of virtual assets or the keys that control them, and operating a centralised or decentralised trading platform that holds client assets or matches trades.
What it takes
- Capital of the higher of a risk-based amount or six months' fixed overheads, or as CIMA sets, plus any buffer CIMA requires
- Client assets identified and segregated from the firm's and its group's assets and protected from third-party creditors
- Custody policy, secure key management, insurance where applicable and regular disclosure of storage methods to clients
- At least three directors, one independent, and at least one with technical expertise in virtual asset operations
- Trading platforms need listing and delisting procedures, client agreements, segregation of client funds and trade surveillance
- KYD 5,000 application fee; grant fee of KYD 30,000 for custody or KYD 100,000 for a trading platform (KYD 3,000 or 10,000 for local companies)
Waiver for supervised persons
CIMA · Virtual Asset (Service Providers) Act, section 16
Firms already licensed or registered by CIMA under another regulatory law, such as banks or securities businesses, whose virtual asset service does not materially change the activity they are supervised for.
What it takes
- Must already be a supervised person under another Cayman regulatory law
- Application describing the nature and scope of the virtual asset service
- CIMA must be satisfied that existing supervision is sufficient to cover the virtual asset service
- Granted only in exceptional circumstances; the firm must comply with any VASP Act provisions CIMA requires and CIMA may revoke the waiver
Sandbox licence (enacted, not yet in force)
CIMA · Virtual Asset (Service Providers) Act, Part 3 (sections 17 to 20), awaiting a commencement order
A temporary licence for innovative virtual asset or fintech services that need closer oversight than a registration or licence provides.
What it takes
- Granted for up to one year and subject to review
- Licensees must follow sandbox principles of honesty, integrity, fair treatment of customers and protection of customer data and assets
- CIMA may limit the technologies, number or type of clients, transaction values and advertising
- CIMA may impose licensee requirements or exempt the firm from some of them
- CIMA's May 2025 licensing policy expressly excludes sandbox applications, pending phase three
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