Caribbean/KY/Comparables
Cayman Islands
Cayman Islands Monetary Authority
Cayman licensed the VASP and then carved the tokenised fund back out. Phase 2 (1 April 2025) requires a full CIMA licence for custody and trading platforms. The Virtual Asset (Service Providers) (Amendment) Act 2026 (Act 4 of 2026, 19 March) defines tokenised mutual and private funds and keeps them in the funds Acts, not in VASP. A Cayman fund token is a digital security. It is not a CIC.
Phase 2
1 Apr 2025
Act 4
19 Mar 2026
VASPs
Selective
Similar regulation
The statute book
Primary instruments, with the RCA job each one actually does. Links open the official text.
- In force
Filter (2) — a fund token is not a VASP issuance
- In force
Conduct overlay on licensed VASPs — not an offering circular
Translation
Rule 100–500 map
| RCA | Peer | Fit | Desk |
|---|---|---|---|
| Rule 100 CIC | Virtual asset under VASPA vs digital equity/investment token under the funds Acts | Inverse | Cayman split the fund token out of VASP in 2026. RCA would exclude it at filter (2). |
| Rule 103 disclosure | No live public-issuance circular for virtual assets | No analogue | Phase 3 (public issuance of new virtual assets) is still ‘in due course.’ |
| Rule 200 $5M | None | No analogue | No startup offering cap. |
| Rule 300 fundraising | Virtual-asset issuance is a VASP activity; fund tokens go through Mutual/Private Funds Acts | Partial | Two doors. The fund door is a registered offering analogue. |
| Rule 400 safe harbor | None | No analogue | No deemed-cessation. |
| Rule 500 preemption | Cayman-only | No analogue | No passport. A CIMA VASP licence is not a US exemption. |
Analysis
What the file is
Cayman’s VASP Act was built as a FATF implementation with a phased licence. Registration from 31 October 2020; full licensing for custody and trading platforms from 1 April 2025, with a 90-day conversion window. Public issuance of new virtual assets is still the missing Phase 3. Meanwhile the Islands remain the default domicile for crypto funds — and in March 2026 Parliament defined tokenised mutual funds and tokenised private funds so those products stay under the funds Acts, not under VASP.
Research
The record
- CIMA’s register is short on purpose. Early-2026 reporting put registered VASPs in the low tens. Selectivity is the fact; it is not a quality stamp on any token those VASPs list.
- Blockchain.com’s July 2026 custody licence is an intermediary fact. It does not authorise an issuance.
- SIBA (Securities Investment Business Act) remains the securities-business door. The 2026 clarifications try to stop double-licensing of the same activity under VASP and SIBA.
Ideation
What to file
- If the raise is a Cayman master/feeder plus a token, attach the 2026 Amendment and say which Act you are in. Staff can then stop asking whether it is a CIC.
- Phase 3, when it comes, is the Cayman analogue to DAIA/VARA issuance. Until it is in force, do not cite Cayman as a public-offer venue for a utility token.
Analysis
What the file is
Cayman’s VASP Act was built as a FATF implementation with a phased licence. Registration from 31 October 2020; full licensing for custody and trading platforms from 1 April 2025, with a 90-day conversion window. Public issuance of new virtual assets is still the missing Phase 3. Meanwhile the Islands remain the default domicile for crypto funds — and in March 2026 Parliament defined tokenised mutual funds and tokenised private funds so those products stay under the funds Acts, not under VASP.
Primary sources on file
Virtual Asset (Service Providers) (Amendment) Act, 2026 (Act 4 of 2026)
Cayman Islands Government/19 Mar 2026/RCA review 10 Sept 2026
Primary regulatory
CIMA Rule and Statement of Guidance — Market Conduct for VASPs
Cayman Islands Monetary Authority/1 Feb 2026/RCA review 10 Sept 2026
Primary regulatory
RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.