News & Insights

VASP Licensing and Continuing Obligations

This guidance note outlines the licensing and continuing obligations for Virtual Asset Service Providers (VASPs) under the Cayman Islands' Virtual Asset (Service Providers) Act (2024 Revision). It covers the two regulatory phases: registration (Phase 1) and licensing (Phase 2), focusing on custody and trading platform services requiring full CIMA licensing from April 2025.

Key obligations include maintaining three directors (one independent), securing CIMA approvals for major changes, compliance with anti-money laundering (AML) and data protection laws, conducting annual financial audits, and adhering to strict reporting and operational standards. CIMA has broad enforcement powers, and significant penalties apply for non-compliance.

VASPs must also prepare for new international reporting under the forthcoming Crypto-Asset Reporting Framework (CARF).

If you would like further information please reach out to our expert attorneys below or call us on +1 (345) 949-3344.

Contact our experts for further advice

Chris Humphries

Managing Director and Head of Funds

Tel:+1 (345) 814-7911

,

Jonathan McLean

Partner and Head of Banking & Regulatory

Tel:+1 (345) 814-7930

VASP Licensing and Continuing Obligations

“Compact independent firm that remains a sound choice for funds counsel in the jurisdiction. Well versed in acting for fund managers, promoters and international investors, providing guidance on the structuring and formation of funds, portfolio transactions and regulatory compliance issues, as well as restructuring and litigation. Notable for its expertise in cryptocurrency funds and related investments.”
Publication Recognition - Chambers & Partners
Stuarts Humphries “impresses clients with its responsiveness, industry knowledge and value for money, especially when compared to some of the larger firms in the domicile.”
Publication Recognition - Legal 500
“Boutique firm offering prompt personal service and expertise covering a wide range of areas.”
“Very responsive team with wide knowledge on funds-related issues, including crypto funds.”
Fund Client Testimonial - IFLR 1000
“They are just phenomenal, the advice that they give strikes a real balance between business and legal issues, and they have real-world solutions instead of sitting in an ivory tower.”
Client Testimonial - Chambers & Partners
“The team gives prompt responses and is able to distill complex questions into easy-to-understand issue.”
Fund Client Testimonial - Legal 500
“The partners roll up their sleeves, take great pride in the work they do and go to great lengths to make themselves available.”
Client Testimonial - Chambers & Partners
“Stuarts Humphries, understands the complex issues we face and the firm offers substantial value in relation to the fees charged.”
Legal 500
“They are very thorough, knowledgeable and most importantly very responsive.”
Fund Client Testimonial - IFLR 1000
“Their strongest point is their customer service. They are incredibly responsive and helpful in meeting our deadlines.”
Fund Client Testimonial - Chambers & Partners
“They provide straightforward, practical advice and the level of attention we receive is very high. They are good at dealing with commercial matters in a commercial context.”
Legal 500

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