Virtual Assets

The Cayman Islands has established itself as a leading jurisdiction for virtual asset service providers (“VASP”), providing a regulatory framework that balances innovation with investor protection. Under the Virtual Asset (Service Providers) Act (Revised) (“VASPA”), entities engaging in virtual asset business must be registered or licensed with the Cayman Islands Monetary Authority (“CIMA”).

Stuarts Humphries advises clients across the full lifecycle of VASP compliance and operation, including registration, licensing, structuring, and ongoing obligations under Cayman law and applicable regulatory requirements. Our experienced team works with start-ups, established businesses, and institutional clients seeking to launch or expand virtual asset services.

Our VASP Services

Our dedicated team provides comprehensive legal advice and support in relation to:

• Company Incorporations: Formation of Cayman entities (exempted companies, LLCs, foundations), registered office and secretarial services, with structures aligned to CIMA’s VASP registration requirements.
• VASP Registration and Licensing: Guidance on applications to CIMA, including registration and licensing requirements under VASPA.
• Governance and Compliance: Advising on anti-money laundering frameworks, internal policies, and governance structures tailored for VASP operations.
• VASP Structuring: Legal advice on structuring VASPs and navigating Cayman Islands regulatory requirements.
• Ongoing Regulatory Support: Assistance with ongoing compliance, reporting obligations, and interaction with regulators.
• Corporate Structuring and Special Economic Zone (“SEZ”) Solutions: Advising on structuring VASP operations within the Cayman Islands’ SEZ to take advantage of tax and business efficiencies. 

Guidance Notes

We have published a series of guidance notes to assist clients in understanding the Cayman Islands’ VASP framework and its practical implications:

• VASP Licensing and Continuing Obligations in the Cayman Islands
• Registration and Obligations of Virtual Asset Service Providers
• Registration of Virtual Asset Service Providers (2020)

Legal Updates and Insights

Our attorneys frequently publish updates and commentary on the evolving regulatory framework for VASPs in the Cayman Islands. Recent insights include:

• 20 September 2025: Cayman Finalises VASP Cancellation Rules and Procedures
• 29 May 2025: VASP Amendment Bill simplifies registration scheme for tokenized funds in Cayman
• 12 March 2025VASP Phase 2 Introduction & Amendments
• 20 December 2024: Update to VASP Application, Rule and SoG
• 29 May 2024: Updated Cayman VASPs Regulatory Framework Guidelines

FAQs

• What is considered a Virtual Asset Service Provider under Cayman law? A VASP is an entity that provides virtual asset services as defined under VASPA, including exchange, transfer, custody, or issuance of virtual assets.
• Do all VASPs need a licence? Not all. Some entities may only require registration, while others must obtain a full licence depending on their activities.
• How long does the registration or licensing process take? Timelines vary depending on the complexity of the business model, but we work closely with clients to ensure efficient preparation and submission of applications.
• Can foreign entities operate VASPs in the Cayman Islands? Yes, provided they meet Cayman’s regulatory requirements and maintain the appropriate legal presence in the jurisdiction.

Videos

Watch our Virtual Assets video below and read more here. To view more content, visit our Video & Podcast Hub.

Our people

Our VASP services are led by experienced attorneys with deep knowledge of Cayman Islands financial regulation and virtual asset legislation.

If you are considering establishing a VASP or require legal advice on Cayman’s virtual asset regulatory framework, please contact us at info@stuartslaw.com, or reach out to one of the attorneys listed.