The Virtual Asset (Service Providers) Act defines the regulatory perimeter for crypto exchanges, custodians, and token issuers operating in or from within the Cayman Islands.

Are you a VASP?

A VASP is an entity providing one or more of the following services for or on behalf of another person:

  • Exchange between virtual assets and fiat currencies.
  • Exchange between one or more forms of virtual assets.
  • Transfer of virtual assets.
  • Safekeeping or administration of virtual assets.
  • Participation in and provision of financial services related to a virtual asset issuance.

Phase 1 vs Phase 2

Currently, Cayman operates under Phase 1 of the VASP regime, which focuses heavily on AML/CFT registration. Entities must register with CIMA, demonstrate robust AML controls, and adhere to the FATF Travel Rule. Phase 2 (licensing for custodians and trading platforms) involves heavier prudential capital requirements.

Proprietary Trading Exception

A crucial distinction: A proprietary trading firm or a crypto hedge fund trading its own capital for its own investors is generally not considered a VASP, as it is not providing services "on behalf of another person."

Entity ProfileLikely Status
Centralized Exchange (CEX)VASP (Registration required)
Crypto Hedge FundNot a VASP (Fund registration required)
Token Issuer (Utility)VASP (Issuance registration required)
Evaluate VASP Capital Needs