Jurisdiction Map
JURISDICTION RELEVANT DIGITAL ASSET LICENSING
BUSINESS LEGISLATION REQUIREMENT
PANAMA No digital asset specific legislation N/A for digital asset, any
but general fintech regulations. business must comply with
existing financial
- Proposed regulations via Bill regulations under its
697 contemplate licensing corporate law
requirements from Panama’s
SBP for virtual asset service
providers
BAHAMAS Digital Asset and Registered License required under
Exchanges Act, 2020 (“DARE”) DARE for digital asset
businesses
CAYMAN Virtual Asset (Service providers) Act, License or registration is
ISLANDS 2020 (“VASP”). mandatory and required
under VASP for VASPs.
- Comprehensive framework for
digital assets and - Distinction exists
cryptocurrency businesses between license and
known in Cayman as VASPs. registration based on
the activity carried out
by the VASP.
Research shows that
distinction centres on
carrying on business
as a VASP
(registration) VS
operating trading or a
custodial service
(license).
BVI Virtual Asset Service Providers Act, License or registration is
2022 (“VASP”) mandatory and required
under VASP for VASPs.
- Comprehensive framework for
digital assets and - Similar to Cayman. A
cryptocurrency businesses distinction exists
known in BVI as VASPs. Similar between license and
to Cayman. registration based on
the activity carried out
by the VASP.
Research shows that
distinction centres on
carrying on business
as a VASP only
(registration) VS
COMPLIANCE REQUIREMENTS DIGITAL ASSET BUSINESS LEGAL RELEVANT PRIVAC REGULATORY POLITICAL AND INTERNATIONAL
CERTAINTY CORPORATE Y BODIES ECONOMIC REPUTATION
STATUTE STABILITY
CARIBBEAN & LATAM
Standard AML and KYC for Ongoing development, Bill 697 has Commercial High Superintendenc Stable and Moderate after Panama
financial services and payments been passed relating to the Code y of Banks of favorable business Papers, known for financial
businesses regulation of cryptocurrencies, Panama (SBP) environment services and offshore
commercial actors in virtual assets, banking
providers of virtual asset services. It
Comprehensive AML and KYC High certainty, with ongoing Companies High Securities Stable and Strong, even after FTX
requirements for digital asset developments. Including revision of Act Commission of favorable business Bahamas is recognized as
businesses under DARE DARE. the Bahamas and financial a leader for its digital asset
services sector regulatory framework
Comprehensive AML and KYC High certainty, with ongoing Companies High Cayman Islands Stable and very Strong, with a well-
requirements for VASPs under developments and amendments Law Monetary well-established established financial
VASP and through the Cayman proposed. Most recently as of Authority (CIMA) financial services services industry and
Islands Proceeds of Crime Act February 13, 2024 sector accompanying regulations
- Entities that conduct
“relevant financial business”
which includes virtual asset
services must comply
Certain AML and KYC High certainty, BVI Financial BVI Business High Financial Stable with well Strong with a well
requirements for VASPs under Services Minister indicates that Companies Services established off established financial
VASP and through the Financing development and industry Act Commission shore business and services sector
and Money Services Act, 2009 consultation related to same may (FSC) financial services
(FMSA) occur, but no amendments are slated sector
or being discussed as of the current
- Registered VASPs are date.
carved out of the FMSA
(VASP s.32(3) & 44(b))
- AML obligations are still
required under the Anti-
Money Laundering
(amendment) Regulations,
2022 and the Anti-Money
Laundering and Terrorist
 operating trading or a Financing (Amendment)
custodial service Code of Practice, 2022
(license).

BERMUDA Digital Asset Business Act, 2018 License is mandatory and
(“DABA”) required under the Digital
Asset Business Act, 2018
- Comprehensive framework for for any entity that carries
digital asset business in out a digital asset
Bermuda. business. Three types of
licenses exist under DABA:
- Test T License – Proof
of Concept (time
limited for pilot or beta
testing activity)
- Modified M License –
Limited Operations
(time limited)
- Full F License – Full-
scale operations
(provision of any and
all digital asset
business activities per
DABA)
Comprehensive AML and KYC
requirements for digital asset
businesses under DABA.
Licensed entities become
regulated financial institutions in
Bermuda and are subject to
Bermudian AML and anti-terrorist
financing legislation.
- Licensed undertakings are
required to take a risk-based
approach to AML and anti-
terrorist financing
compliance.
High certainty. Research indicates no Companies High Bermuda Stable with a Strong and has a strong
proposed developments or Act Monetary strong focus on insurance industry.
messaging related to the same as of Authority (BMA) fintech and digital Bermuda is also noted for
the current date. assets having taken a proactive
approach to digital asset
regulation, having been
one of the earlier
Caribbean jurisdictions to
construct a legislative
scheme related to digital
assets.

CURACAO* No digital asset specific legislation N/A for digital asset, any Standard AML and KYC for Ongoing developments Curacao Civil High Central Bank of Moderately Stable Moderate, not as well
but general financial regulation for business must comply with financial services and payments Code Curacao and known or established as
corporations existing financial businesses Sint Maarten other Caribbean
regulations under its jurisdictions.
corporate law

BARBADOS No digital asset specific legislation
but general financial regulation for
corporations
N/A for digital asset, any
business must comply with
existing financial
regulations under its
corporate law
Standard AML and KYC for
financial services and payments
businesses
Ongoing development. Barbados Companies Moderate Financial Stable Strong, well established
Stock Exchange has put out a draft Act Services insurance and financial
guidance note for the listing of digital Commission services sector. Barbados
assets, the ISM Guidance Note – (FSC) and is looking to become a
Application of Special Listing Facility Barbados Stock leader in digital asset
for Digitial Financial Assets and the Exchange listings.
ISM Special Listing Facility – Digital
Assets – Series 9000 Rules.
- Barbados is exploring the
opportunity to become a leader
in the listing of digital assets
and the provision of the facilities
to facilitate the trading of the
same.
- These proposed frameworks
are pending approval.
-

EMEA

DIFC Digital Assets Law (DIFC Law No 2 of Currently the DIFC is N/A Uncertain related to VASP, however Companies Dubai Financial Very Stable Very strong
2024) exempt from VARA legal certainty in DIFC related to Law Services
registrations under Law digital assets as property Authority
- World’s first digital asset law
 that provides legal certainty for No. (4) noted below.
digital assets as a form of
property in the UAE
Currently no VASP statute exists in
DIFC

UAE Law No. (4) of 2022 Regulating VASP license from VARA Comprehensive AML and KYC High, with ongoing developments UAE High Dubai Financial Very Stable Very strong as global
Virtual Assets in the Emirate of Dubai required in order to requirements for digital asset Commercial Services business hub, with
conduct VASP activities businesses under DMCC Companies Authority supportive legislation and
- Comprehensive framework for within Dubai law (DFSA) and regulations
virtual asset service providers DMCC Authority
and cryptocurrency businesses
known as VASPs in UAE.
Similar to Cayman.
Abu Dhabi
Global Market
(ADGM)

Dubai Silicon
Oasis (DSOA)
Virtual Assets
Regulatory
Authority
(VARA)
CYPRUS TBD
ESTONIA Money Laundering and Terrorist License required for digital Comprehensive AML and KYC High, with ongoing developments Commercial Moderate Financial Moderately Stable Moderate, up and coming
Financing Prevention Act asset business under the requirements for digital asset Code Supervision jurisdiction for digital
Virtual Currency Service businesses under the Money Authority economy which includes
- Comprehensive framework for Providers Act Laundering and Terrorist digital asset businesses.
digital asset businesses known Financing Prevention Act
as “virtual currency services” in - Statute is robust and
Estonia difficult to navigate Estonian
compared to other Financial
jurisdictions listed Intelligence Unit
here1 (RAB)

SEYCHELLES No VASP specific legislation yet, but
it is expected to come into force
shortly.
N/A for digital asset, any
business must comply with
existing financial
regulations under its
corporate law
Standard AML and KYC for
financial services and payments
businesses
Ongoing developments related to International High Financial Moderately Stable Moderate, has a financial
VASP statute, the Virtual Asset Business Services services sector that is semi
Service Providers Bill, 2024 is in Companies Authority (FSA) established and is growing
draft form and is within its second Act
round of consultation

HONG KONG Anti-Money laundering and Counter Licensing required under Comprehensive AML and KYC High, with ongoing developments to Companies High Securities and Moderately stable, Strong, major financial hub
Terrorist Financing (Amendment) the Securities and Futures requirements for digital asset the AMLO Ordinance Futures with political globally and in Asia with
Ordinance2 (“AMLO”) Ordinance is required for businesses under the AMLO Commission challenges mostly supportive regulations
businesses compared (SFC) from tension with
- Provides comprehensive “Virtual Asset services”. Peoples Republic
legislation for digital asset of China
businesses defined as “virtual - These are defined to
service” be exchanges where

1
https://www.riigiteataja.ee/en/eli/ee/518012019004/consolide/current
2
https://www.legco.gov.hk/yr2022/english/bills/b202206241.pdf
 per Schedule 3B the
following are met
o offers to sell or
purchase VAs are
regularly made or
accepted in a way
that forms or results
in a binding
transaction; or
o persons are
regularly introduced
or identified to other
persons to allow
them to negotiate or
conclude sales or
purchases of VAs in
a way that forms or
results in a binding
transaction; and
o where client money
or client VAs come
into direct or indirect
possession of the
person providing
such services
SINGAPORE Payment Services Act, 2019 Licensing required for Comprehensive AML and KYC High, with ongoing developments Companies High Monetary Very stable Strong, major fintech and
digital payment token requirements for digital asset Act Authority of finance hub globally and in
- Provides comprehensive service providers under the businesses under the Payment Singapore Asia
legislation for “digital payment Payment Services Act Services Act
token service providers” that
mainly relates to echanges.