On March 13, 2025, Curaçao enacted the National Ordinance on the Supervision of Virtual Asset Service Providers (Landsverordening toezicht virtuele activa dienstverleners — the VASP Act). The Act establishes a formal licensing framework for virtual asset activity and designates the Centrale Bank van Curaçao en Sint Maarten (CBCS) as the supervising authority. Unlicensed virtual asset activity in or from Curaçao is no longer permitted.
What Activities Require a Licence
The VASP Act covers five categories of virtual asset activity: fiat-to-crypto exchange, crypto-to-crypto exchange, virtual asset transfer services, custodial wallet services, and the facilitation of any of these activities. Any entity carrying out these activities in or from Curaçao must hold a CBCS licence under the Act. The licensing requirement applies regardless of whether the entity is incorporated in Curaçao or operating from Curaçao into other markets.
AML/CFT Obligations for VASP Operators
The VASP Act directly links VASP licensees to Curaçao's AML/CFT framework. VASP operators carry the same AML/CFT obligations as traditional financial institutions under Curaçao law — specifically under the identification ordinance (LID) and the unusual transactions reporting ordinance (LvMOT). This means VASP operators must maintain CDD and EDD procedures, screen for PEPs and sanctions, file unusual transaction reports, and maintain the internal AML/CFT governance infrastructure expected of regulated financial entities.
Impact on Corporate and Trust Service Providers
Corporate service providers and trust service providers that assist VASP clients — including those that provide incorporation, directorship, or administration services to VASP-licensed entities — should review whether their service scope now needs to extend to address VASP licensing and AML/CFT requirements. Providing services to an unlicensed VASP client creates a compliance risk for the service provider. Service providers should verify the licensing status of any virtual asset clients in their portfolio.
What To Do Now
If your entity carries out virtual asset activities in or from Curaçao and you do not hold a CBCS licence under the VASP Act, contact CBCS or your regulatory adviser immediately. If you are a corporate service provider with virtual asset clients, verify their CBCS licensing status. Ensure your AML/CFT procedures cover VASP-specific obligations under the LID and LvMOT. Review client onboarding documentation for VASP clients to confirm it meets the applicable CDD and EDD standards.