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| Dimension |
Pinned 🇰🇾 Cayman Islands partly open Verified 2026-08-15
|
🇬🇬 Guernsey
partly open
Verified 2026-10-01
|
|---|---|---|
| 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. | The Lending, Credit and Finance (Amendment) Rules, 2026 were made on 9 September 2026 and took effect on 1 October 2026. They removed the blanket restriction on VASPs serving retail customers, removed the VASP-specific environmental reporting requirement, and reduced duplicate licensing for firms already regulated by the GFSC. The GFSC says work continues on stablecoins, digital custody and technology for anti-financial-crime compliance. |
| 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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