What is the Virtual Asset Business Act (VABA)?

The VABA, which was enacted in 2022, and became effective from May 31, 2025, establishes a regulatory framework for virtual asset businesses operating in or from within St. Vincent and the Grenadines (SVG). It aims establish a comprehensive framework to ensure transparency, investor protection, and compliance with international standards by Virtual Asset Service Providers (VASPs) or Virtual Asset Businesses (VABs). The VABA applies to all persons that intend to or are currently providing virtual asset services in or from within SVG. 

• What are virtual assets?

The VABA defines “Virtual Assets” as digital representations of value that can be digitally traded or transferred and can be used for payment or investment purposes.

Digital representations of fiat currencies (legal tender) or security are not considered Virtual Assets.

• What activities constitute a “Virtual Asset Business”?

For the purposes of the VABA, a Virtual Asset Business (VAB) is an entity offering or operating the following services:

• Exchange between virtual assets and fiat currencies
• Exchange between different virtual assets
• Transfer of virtual assets
• Custody or administration of virtual assets or instruments enabling control
• Provision of financial services related to virtual asset issuance or sale

Only Business Companies (BCs) and Limited Liability Companies (LLCs) are eligible to apply for registration as a VAB.

4.   Can a SVG BC or LLC carry on VAB without the need for registration under the VABA, if it is carrying on its activities outside of SVG?

No. Registration is required if the LLC or BC is registered or incorporated in SVG regardless of where the virtual asset services are being undertaken from.

BCs and LLCs offering VAB or related services are required, prior to any service offering being made in a foreign jurisdiction, to ensure that there is no licence or authorization required. If a country requires further authorisation in order to offer their services, the BC or LLC must ensure that they obtain the requisite licence or authorization in that jurisdiction as well.

5.  Who are exempt from registration under the VABA?

• A company which only provides technology (e.g., cloud storage for crypto data)
• A private individual making personal crypto transfers
• A business using cryptocurrency for its own transactions only

• Can persons who were operating as VABs upon commencement of the VABA continue to do so?

No. BCs and LLCs providing virtual asset services prior to the Act coming into force are required to apply for registration.   BCs and LLCs found to be operating after the transition period and having failed to submit a complete application will be in breach of the VABA and subject to enforcement action, including but not limited to striking off procedures and imposition of fines/ penalties.

• How do I apply for registration?

  Applications must be submitted through a Registered Agent licensed by the FSA. The process includes:

• Establishing a Business Company or Limited Liability Company
• Completing the application form
• Providing due diligence documents and references
• Submitting a business plan and financial statements
• Paying the application fee

Upon approval, the FSA will issue a Certificate of Registration which is valid until 31^st December of the year of issuance. The license is renewable by 31^st January of the ensuing year.

• How long does the registration process take?

The application process typically takes approximately 90 days, provided all documentation is complete and accurate.

•  What are the key registration requirements?

• Application Fee: EC$ 4,000
• Registration Fee: EC$ 12,000
• Renewal fee: EC$ 12,000 annually
• Statutory Deposit: USD 100,000 or 25% of total client financial obligations, whichever is greater
• Capital Requirements: EC$300,000
• Professional Indemnity Insurance: Minimum coverage of EC $ 300,000
• Principal Representative: Mandatory for foreign entities; must be an individual who is resident in SVG
• Fit-and-Proper Assessment: For directors, beneficial owners, and key personnel
• Business Plan: financial projections (5 years for new businesses)
• Audited Financial Statements: For existing companies, 3 years of audited financials are required
• Policies: AML/CFT policies, risk management framework, IT and cyber security, consumer protection
• . What Elements are to be included in the Business Plan?

• Description of the objectives of the business;
• Proposed customer base and target market;
• Feasibility study;
• Organizational structure, inclusive of management structure and staffing requirements and the power and duties of officers;
• AML/CFT Policies and provisions, including data management and protection, security access control and cyber security safeguards;
• Description of internal systems and controls;
• Copy of ownership structure, including group members and affiliates where applicable;
• Risk management systems and policies;
• Five-year financial projections.

1.  What other legislation are VABs required to comply with?

In addition to the VABA, registered VABs are required to comply with the Anti-Money Laundering and Countering the Financing of Terrorism Act Regulations 2014.

1. What ongoing compliance obligations must registered businesses fulfill?

Registered virtual asset businesses are required to:

• Submit yearly audited financial statements and IT and cyber security audit reports;
• Provide yearly updates to all policy documents;
• Provide quarterly reports providing the number of accounts held and value of the accounts held;

• Submit quarterly and annual reports detailing AML/CFT compliance;
• Proof of valid Professional Indemnity insurance on a yearly basis;
• Maintain a minimum paid-up capital of EC $ 50,000;
• Comply with the “Travel Rule” by collecting and monitoring sender/receiver information for transactions.
•  What is the Travel Rule?

This Travel Rule, which aligns with the Financial Action Task Force (FATF) guidelines, aims to enhance transparency, prevent money laundering, and combat the financing of terrorism in the cryptocurrency space. The Travel Rule requires all VABs to share certain originator and beneficiary information when conducting virtual asset transfers on behalf of a third party.

• Originator:
• name of both parties.
• The account numbers of both parties, if an account is used.
• The originator’s:
• identification number or date and place of birth.
• physical address;
• Identification number;

customer

• The unique transaction reference number (“UTR”) if no account is used to process the transfer.

• Beneficiary VASP Requirements:
• name of both parties.
• The account numbers of both parties, if an account is used.
• The beneficiary’s

1. physical address;
2. Identification number;
3. customer identification number or date and place of birth.

• The UTR if no account is used to process the transfer.

1.  Can I operate without a physical office in SVG?

Yes, but you must appoint a Principal Representative who is a resident of SVG and maintain a local business address.