FINANCIAL SERVICES AUTHORITY
SAINT VINCENT & THE GRENADINES
CIRCULAR NO. 1
TO: All Virtual Asset Service Providers & Interested Persons
FROM: Financial Services Authority
SUBJECT: Implementation of the Virtual Asset Business Act & Commencement of the Registration Process for Virtual Asset Businesses
DATE: May 27, 2025
The Financial Services Authority (the “Authority”) wishes to advise that, pursuant to the Virtual Asset Business Act No. 9 of 2022, (the “VABA”) as amended, the application process for the registration of virtual asset businesses in or from within Saint. Vincent and the Grenadines will formally commence from June 2nd 2025.
Registration Requirements:
Entities engaged in virtual asset services, as defined under the VABA, are required to register with the Authority. This includes services such as:
1. Exchange between virtual assets and fiat currencies;
2. Exchange between different types of virtual assets;
3. Transfer of virtual assets;
4. Custody or administration of virtual assets or instruments enabling control over virtual assets;
5. Participation in and provision of financial services related to an issuer’s offer or sale of a virtual asset.
Application Process:
Applicants are required to submit the application form along with the necessary documentation and application fee of EC$4,000. The application form and checklist are attached and will also be available on the Authority’s website (www.fsasvg.com).
Regulations and Guidanceon the ongoing requirements and obligations of registrants will follow.
Virtual Asset Business Act, 2022
This VABA introduces a comprehensive regulatory framework for virtual asset business activities conducted in or from within Saint Vincent and the Grenadines. The VABA sets out the requirements for registration, compliance, supervision, and ongoing obligations for entities engaged in virtual asset business including virtual asset service providers (VASPs).
Virtual Asset Business (Amendment) Act, 2025
On April 28th, 2025 the Act was amended to update and clarify certain provisions of the VABA. The key amendments are as follows:
1. Commencement date
The Amendment Act sets out the date for the commencement of the Act and makes it clear that the Act comes into force on the 31st day of May, 2025.
2. Proof of Incorporation (Section 6(3)(d))
The amendment clarifies that applicants for registration must provide proof of incorporation or formation under either:
▪ The Business Companies (Amendment and Consolidation) Act, or
▪ The Limited Liability Companies Act.
3. Regulatory Compliance References (Sections 18(1)(a) & 19(1)(d))
The language is expanded to include not just the Act, but also Regulations made under it, ensuring that regulatory obligations apply broadly across both the Act and any subordinate legislation.
4 . Extension of transitional Period (Section 24(2))
The transitional period for the making of applications for registration for VASPs which were in operation prior to the commencement of the Act is extended from seven (7) days to thirty (30) days, providing more flexibility for compliance.
Conclusion
In accordance with the Act, all existing entities currently engaged in virtual asset activities, including those incorporated as Limited Liability Companies (LLCs) or Business Companies (BCs) engaged in virtual asset or related business, are required to submit an application for registration to the Authority within thirty (30) days of the coming into force of the Act, that is, by July 31, 2025. Entities that fail to apply within the prescribed period will be subject to an administrative striking off.
The Authority therefore, strongly encourages all relevant entities to review the legislation and guidance in detail and to take immediate steps to ensure timely compliance with the new legal requirements. Registered Agents are advised to begin familiarizing themselves with the provisions of the Act and to prepare their clients accordingly. Further guidance will be provided to ensure a smooth transition into the new regulatory framework.
Should you have any questions in the interim, please contact the Authority at 456 2577 or kjackson@svgfsa.com or info@svgfsa.com.
We thank you for your attention and continued cooperation.