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| Dimension |
Pinned 🇧🇲 Bermuda partly open Verified 2026-08-15
|
🇻🇬 British Virgin Islands (BVI)
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | Digital Asset Business (DAB) licence under the Digital Asset Business Act 2018 (DABA), with three tiers: Class T (Test/sandbox licence for early-stage/proof-of-concept businesses, time-limited ~3-12 months), Class M (Modified licence for limited-scope/lower-risk operations, a stepping stone to full authorization), and Class F (Full, unrestricted licence covering the complete range of digital asset business activities, issuance, exchange, custody, payment services, dealing as principal, etc., with no expiry, subject to ongoing supervision). | VASP registration under the Virtual Assets Service Providers Act, 2022 (in force 1 February 2023). Three categories: (1) General VASP registration (e.g. transfer/brokerage/advisory services not falling into the other two categories), (2) Virtual Assets Custody Service registration, (3) Virtual Assets Exchange registration. Entities can hold multiple categories if they pay the applicable fee for each. ICO/ITO token issuance alone does not require registration if no other regulated virtual asset service is provided (per FSC Circular 43/2025 FAQ). |
| Regulator | Bermuda Monetary Authority (BMA) | British Virgin Islands Financial Services Commission (BVI FSC) |
| Capital requirement | Bermuda capital requirement is included in the £349 pass. | British Virgin Islands (BVI) capital requirement is included in the £349 pass. |
| Timeline to authorisation | Bermuda timeline to authorisation is included in the £349 pass. | British Virgin Islands (BVI) timeline to authorisation is included in the £349 pass. |
| Local substance | Bermuda local substance is included in the £349 pass. | British Virgin Islands (BVI) local substance is included in the £349 pass. |
| Application cost | Bermuda application cost is included in the £349 pass. | British Virgin Islands (BVI) application cost is included in the £349 pass. |
| Ongoing cost | Bermuda ongoing cost is included in the £349 pass. | British Virgin Islands (BVI) ongoing cost is included in the £349 pass. |
| Passporting | Bermuda passporting is included in the £349 pass. | British Virgin Islands (BVI) passporting is included in the £349 pass. |
| MiCA CASPs approved | Bermuda mica casps approved is included in the £349 pass. | British Virgin Islands (BVI) mica casps approved is included in the £349 pass. |
| Key restrictions | Bermuda key restrictions is included in the £349 pass. | British Virgin Islands (BVI) key restrictions is included in the £349 pass. |
| Recent changes | In January 2026, at the WEF Annual Meeting in Davos, the Government of Bermuda announced a partnership with Circle and Coinbase (and Stellar) to build what it describes as the world's first 'fully onchain' national economy, including plans for a sovereign Bermuda digital dollar. The BMA has begun real-world pilots, airdropping USDC to residents, enabling payments at a pop-up marketplace, and preparing to accept digital assets for government fees. Bermuda also hosts regulated derivatives operations tied to major exchanges including Coinbase and Kraken. The BMA's 2025 annual report shows licensed digital asset businesses rose to 49 by end of 2025 (up from 36 a year earlier). The DABA Code of Practice was also updated in 2024 with more detailed marketing/promotion and governance requirements. Bitcoin Suisse (International) Ltd was granted a Class F digital asset business licence with Class B investment business registration, reported 13 May 2026, pre-operational pending standard conditions. On tokenisation, the BMA issued a stakeholder letter on 30 March 2026 and a consultation paper on 9 April 2026 (feedback to 30 June 2026); on 21 July 2026 it opened a further consultation on letting certain insurers, ILS structures and investment funds use fully fiat-backed stablecoins for subscriptions, treasury and premium or claims payments (comments to 30 September 2026). | November 2025: FSC issued Industry Circular 43 of 2025, publishing a comprehensive 'Understanding Virtual Assets and VASP Regulation' FAQ document clarifying scope (e.g., confirming pure ICO/ITO token issuance without other regulated activity does not require VASP registration). March 2025: BVI launched the Virtual Asset Service Providers Advisory Committee (VASPAC), a public-private body to enhance regulation/supervision of the sector, first meeting 27 March 2025. The FSC's Compliance Inspection Unit began a major round of onsite VASP/TCSP/Investment Business inspections in 2025 running through Q1 2026, focused on AML/CFT/CPF controls, internal audit, and staff training. |
| Difficulty rating | Bermuda difficulty rating is included in the £349 pass. | British Virgin Islands (BVI) difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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