As of 31 July 2025, there were 19 registered VASPs carrying out virtual asset service business in or from the Cayman Islands. Virtual asset service business includes the transfer of virtual assets, custody services, issuance of virtual assets, exchange of virtual assets for fiat currency or other virtual assets, or the provision of financial services relating to the sale of virtual assets.
CIMA takes a risk-based approach in its supervision of VASPs and conducts both on-site inspections and desk-based reviews. VASPs must also submit an annual AML Return (formally known as the AML Survey) and the quarterly Travel Rule Return, which, amongst other things, allows CIMA to analyse data of transactions conducted by VASPs.
In highlighting its key findings, CIMA noted good compliance levels in many areas following the first round of inspections of VASPs. However, there were notable deficiencies, particularly around customer risk assessment, sanctions screening, due diligence, transaction monitoring and record keeping. CIMA emphasised that breaches of the AML requirements can lead to enforcement action and administrative fines.
Maples Group has considerable experience advising VASPS and other CIMA-regulated entities on inspections and reviews as well as in relation to ongoing compliance. Please reach out if we can be of assistance.