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| Dimension |
Pinned 🇰🇾 Cayman Islands partly open Verified 2026-08-15
|
🇬🇬 Guernsey
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | Two-tier regime under the Virtual Asset (Service Providers) Act (VASP Act, as amended). Phase 1 (in force since 2020): VASP Registration, required for virtual asset services generally that are not custody or trading-platform operation; AML/CFT-focused, lighter touch. Phase 2 (in force since 1 April 2025): VASP Licence, mandatory for entities operating a virtual asset custody service or a virtual asset trading platform; registration is no longer available for these two activity categories. A narrow waiver from registration/licensing is available for entities already licensed under another Cayman regulatory law. | Part III VASP Licence under the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022 ('LCF Law'). Covers virtual asset exchange, transfer, safekeeping/custody, administration, and issuance/ICO services. This is a genuine substantive licensing regime (not merely AML registration), which came into full effect 1 July 2023 (application window opened 1 February 2023). |
| Regulator | Cayman Islands Monetary Authority (CIMA) | Guernsey Financial Services Commission (GFSC). |
| Capital requirement | Cayman Islands capital requirement is included in the £349 pass. | Guernsey capital requirement is included in the £349 pass. |
| Timeline to authorisation | Cayman Islands timeline to authorisation is included in the £349 pass. | Guernsey timeline to authorisation is included in the £349 pass. |
| Local substance | Cayman Islands local substance is included in the £349 pass. | Guernsey local substance is included in the £349 pass. |
| Application cost | Cayman Islands application cost is included in the £349 pass. | Guernsey application cost is included in the £349 pass. |
| Ongoing cost | Cayman Islands ongoing cost is included in the £349 pass. | Guernsey ongoing cost is included in the £349 pass. |
| Passporting | Cayman Islands passporting is included in the £349 pass. | Guernsey passporting is included in the £349 pass. |
| MiCA CASPs approved | Cayman Islands mica casps approved is included in the £349 pass. | Guernsey mica casps approved is included in the £349 pass. |
| Key restrictions | Cayman Islands key restrictions is included in the £349 pass. | Guernsey key restrictions is included in the £349 pass. |
| Recent changes | Phase 2 licensing (custody and trading platforms) came into force 1 April 2025, with a 90-day transition deadline of 30 June 2025 for existing registrants to convert to a licence. CIMA updated the VASP application forms, Rule, and Statement of Guidance in December 2024 ahead of Phase 2. From 1 December 2025, CIMA introduced a new quarterly financial reporting requirement via the REEFS portal, layered on top of the existing annual audited accounts requirement. CIMA conducted a Thematic Desk-Based Review of 11 regulated VASPs (September 2024-February 2025), with findings published November 2025 and a further legal briefing in February 2026, identifying gaps in board composition, cybersecurity governance, staff training, and sanctions-screening practices. A Phase 3 is expected but not yet commenced as of mid-2026. | On 24 July 2026 the GFSC published its Supporting Growth with Digital Finance feedback paper. Revised Part 10 rules are intended to take effect on 1 October 2026, permitting VASPs to serve retail customers and deleting the VASP-specific environmental declaration. Retail-facing firms must notify the GFSC and hold proportionate resources. Separate relief from dual licensing for some existing regulated firms remains proposed, with the section 40 notice consultation closing 31 August 2026. Stablecoin rules are expected in autumn 2026. |
| Difficulty rating | Cayman Islands difficulty rating is included in the £349 pass. | Guernsey 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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