Regulatory Intelligence
AI-maintained daily updates on crypto regulations worldwide. Newest first — page 35 of 43.
NBR Researching CBDC: The National Bank of Rwanda has publicly stated that it is actively exploring the potential...
NBR Researching CBDC: The National Bank of Rwanda has publicly stated that it is actively exploring the potential issuance of a Central Bank Digital Currency (CBDC). This research is ongoing.
Potential Impact: The NBR's exploration of a CBDC often reflects a desire for a state-controlled, secure, and eff...
Potential Impact: The NBR's exploration of a CBDC often reflects a desire for a state-controlled, secure, and efficient digital currency, which could potentially reduce the perceived need or appetite for privately issued stablecoins. A CBDC could offer a regulated alternative for digital payments, possibly leading to a more restrictive stance on private stablecoins to avoid competition or systemic risks. There is no direct regulatory "interaction" yet as the CBDC is still in the research phase.
Partial/Cautionary: Rwanda does not have a comprehensive regulatory framework for cryptocurrencies, nor does it i...
Partial/Cautionary: Rwanda does not have a comprehensive regulatory framework for cryptocurrencies, nor does it impose an outright ban. Instead, it maintains a cautionary stance, primarily through warnings from the central bank, highlighting the risks associated with virtual assets. The focus is currently on consumer protection, financial stability, and leveraging existing AML/CFT legislation.
Developing: There is an ongoing recognition of fintech innovation, and discussions are underway regarding future ...
Developing: There is an ongoing recognition of fintech innovation, and discussions are underway regarding future regulatory frameworks that might encompass virtual assets.
High Risk Warnings: The National Bank of Rwanda has consistently advised the public that engaging in virtual asse...
High Risk Warnings: The National Bank of Rwanda has consistently advised the public that engaging in virtual asset activities carries significant risks, including price volatility, lack of consumer protection, potential for fraud, and the absence of any regulatory recourse in case of loss.
No Specific Licensing: There is currently no specific licensing regime for Virtual Asset Service Providers (VASPs...
No Specific Licensing: There is currently no specific licensing regime for Virtual Asset Service Providers (VASPs), including exchanges, custodians, or issuers of virtual assets. Entities engaging in such activities do so outside of the formal financial regulatory framework.
De Minimis Threshold (for certain scenarios): While the law requires information for all transfers, FATF guidance...
De Minimis Threshold (for certain scenarios): While the law requires information for all transfers, FATF guidance allows for a de minimis threshold (typically USD/EUR 1,000) below which the receiving VASP may not need to obtain the originator information unless there is suspicion of ML/TF or the transfer is associated with a higher-risk scenario. However, the originating VASP still has obligations to collect and transmit this information. Rwanda's Article 23 generally mandates information for all transfers, placing the burden on both originating and receiving entities. Further specific implementing regulations or guidance from the National Bank of Rwanda (BNR) or the Financial Intelligence Centre (FIC) would clarify any exact de minimis for specific types of lower-risk transactions, but the default expectation is full compliance.
Administrative Sanctions: Imposed by regulatory bodies like the National Bank of Rwanda (BNR) or the Financial In...
Administrative Sanctions: Imposed by regulatory bodies like the National Bank of Rwanda (BNR) or the Financial Intelligence Centre (FIC), which can include warnings, fines, suspension of licenses, or withdrawal of licenses.
Fines: Significant monetary penalties for legal persons, potentially ranging from millions to hundreds of million...
Fines: Significant monetary penalties for legal persons, potentially ranging from millions to hundreds of millions of Rwandan Francs (RWF), depending on the severity and nature of the breach.
Sanctions Screening: Implement controls to screen customers and transactions against national and international s...
Sanctions Screening: Implement controls to screen customers and transactions against national and international sanctions lists (e.g., UN Security Council sanctions lists).
Central Bank of Solomon Islands (CBSI): The primary regulatory body.
Central Bank of Solomon Islands (CBSI): The primary regulatory body.
Central Bank of Solomon Islands Act 2012: Governs the powers and functions of the CBSI.
Central Bank of Solomon Islands Act 2012: Governs the powers and functions of the CBSI.
Financial Institutions Act 1998: Regulates financial institutions and banking activities.
Financial Institutions Act 1998: Regulates financial institutions and banking activities.
Asset Freezing: VASPs must immediately freeze any funds or other assets (including virtual assets) belonging to, ...
Asset Freezing: VASPs must immediately freeze any funds or other assets (including virtual assets) belonging to, or controlled by, designated persons or entities appearing on UN sanctions lists. This includes funds derived from or generated by such assets.
United Nations Financial Sanctions Act 2017: Accessible via the Pacific Islands Legal Information Institute (PacL...
United Nations Financial Sanctions Act 2017: Accessible via the Pacific Islands Legal Information Institute (PacLII): https://www.paclii.org/sb/legis/num_act/unfsa2017326/
US Persons and Nexus: Any VASP that is a "US Person" (US citizen, resident, entity incorporated in the US or subj...
US Persons and Nexus: Any VASP that is a "US Person" (US citizen, resident, entity incorporated in the US or subject to US jurisdiction) must comply with all OFAC sanctions globally.
US Financial System Interaction: Even non-US VASPs risk penalties if their transactions involve a US nexus (e.g.,...
US Financial System Interaction: Even non-US VASPs risk penalties if their transactions involve a US nexus (e.g., using a US-based exchange, stablecoin issued by a US entity, US dollar-denominated transactions cleared through the US financial system).
EU Persons and Nexus: Similarly, VASPs that are "EU Persons" or have a nexus to the EU (e.g., serving EU customer...
EU Persons and Nexus: Similarly, VASPs that are "EU Persons" or have a nexus to the EU (e.g., serving EU customers, using EU-based infrastructure, dealing with euro-denominated virtual assets) must comply with EU sanctions.
Correspondent Banking and De-risking: Non-compliance with OFAC/EU sanctions by a Solomon Islands VASP can lead to...
Correspondent Banking and De-risking: Non-compliance with OFAC/EU sanctions by a Solomon Islands VASP can lead to de-risking by global financial institutions (including banks and larger crypto exchanges), effectively cutting off access to the international financial system.
EU Sanctions Map: https://www.sanctionsmap.eu/#/main
EU Sanctions Map: https://www.sanctionsmap.eu/#/main
Implement Risk-Based Screening: Conduct ongoing screening of their customers, beneficial owners, and transaction ...
Implement Risk-Based Screening: Conduct ongoing screening of their customers, beneficial owners, and transaction counterparties against the relevant sanctions lists (UN, and prudently, OFAC/EU lists).
Know Your Customer (KYC) / Customer Due Diligence (CDD): Integrate sanctions screening into their CDD processes f...
Know Your Customer (KYC) / Customer Due Diligence (CDD): Integrate sanctions screening into their CDD processes for all new and existing customers.
Transaction Monitoring: Monitor transactions for patterns or attempts to circumvent sanctions.
Transaction Monitoring: Monitor transactions for patterns or attempts to circumvent sanctions.
Record-Keeping: Maintain records of all screening activities and any sanctions hits, including the actions taken.
Record-Keeping: Maintain records of all screening activities and any sanctions hits, including the actions taken.
Internal Controls: Establish robust internal policies, procedures, and training programs to ensure effective sanc...
Internal Controls: Establish robust internal policies, procedures, and training programs to ensure effective sanctions compliance.
Fines: Substantial monetary penalties. For example, the UN Financial Sanctions Act 2017 outlines penalties for br...
Fines: Substantial monetary penalties. For example, the UN Financial Sanctions Act 2017 outlines penalties for breaching a financial sanction, which can be significant.
Imprisonment: Individuals found in violation of sanctions laws can face terms of imprisonment.
Imprisonment: Individuals found in violation of sanctions laws can face terms of imprisonment.
United Nations Financial Sanctions Act 2017, Part 4 (Offences and Penalties).
United Nations Financial Sanctions Act 2017, Part 4 (Offences and Penalties).
Lack of Specific Legislation: Without a dedicated framework, enforcement actions are harder to initiate.
Lack of Specific Legislation: Without a dedicated framework, enforcement actions are harder to initiate.
Companies Act 2009: This is the primary legislation that would be used to define "securities."
Companies Act 2009: This is the primary legislation that would be used to define "securities."
Central Bank of Solomon Islands (CBSI): While not providing specific crypto securities guidance, their website co...
Central Bank of Solomon Islands (CBSI): While not providing specific crypto securities guidance, their website contains general warnings and statements regarding cryptocurrencies.
If a stablecoin were to be deemed a form of e-money or deposit-taking activity, it might eventually fall under the ...
If a stablecoin were to be deemed a form of e-money or deposit-taking activity, it might eventually fall under the prudential requirements enforced by the CBSI for licensed financial institutions, but this would require a specific determination and potentially new regulations.
No specific licensing regime. There is no dedicated licensing regime for stablecoin issuers in the Solomon Islands.
No specific licensing regime. There is no dedicated licensing regime for stablecoin issuers in the Solomon Islands.
Entities wishing to operate payment systems or conduct financial services that could involve stablecoins would need...
Entities wishing to operate payment systems or conduct financial services that could involve stablecoins would need to ascertain if their activities fall under the purview of the Central Bank of Solomon Islands (CBSI) under the Central Bank of Solomon Islands Act 1976 (as amended) or the Financial Institutions Act 1998. However, neither of these acts explicitly mentions or provides a framework for virtual asset issuers.
Central Bank of Solomon Islands (CBSI) website: https://www.cbsi.com.sb/ (The primary financial regulator, though...
Central Bank of Solomon Islands (CBSI) website: https://www.cbsi.com.sb/ (The primary financial regulator, though no crypto-specific section is available as of the last check).
Not explicitly defined. Without specific legislation governing stablecoins, there are no legally mandated redempt...
Not explicitly defined. Without specific legislation governing stablecoins, there are no legally mandated redemption rights for stablecoin holders in the Solomon Islands.
No active CBDC development or interaction. The Solomon Islands is not known to be actively exploring or developin...
No active CBDC development or interaction. The Solomon Islands is not known to be actively exploring or developing a Central Bank Digital Currency (CBDC).
None to Partial (with Strong Cautionary Stance): Solomon Islands does not have a comprehensive regulatory framewo...
None to Partial (with Strong Cautionary Stance): Solomon Islands does not have a comprehensive regulatory framework specifically for virtual assets. The approach is primarily one of public warning and monitoring by the Central Bank, rather than explicit regulation, licensing, or outright ban of the underlying technology or trading (though no legal protections exist). There are efforts to address AML/CTF risks, but virtual assets are not yet fully integrated into existing financial laws.
Central Bank of Solomon Islands Act 2012 (and any subsequent amendments):
Central Bank of Solomon Islands Act 2012 (and any subsequent amendments):
Anti-Money Laundering Act 2002 (and subsequent amendments):
Anti-Money Laundering Act 2002 (and subsequent amendments):
Central Bank of Solomon Islands (CBSI) Public Notice on Cryptocurrencies (26th July 2021):
Central Bank of Solomon Islands (CBSI) Public Notice on Cryptocurrencies (26th July 2021):
The Seychelles VASP Act does not define a separate category of "qualified custodian" distinct from a general VASP tha...
The Seychelles VASP Act does not define a separate category of "qualified custodian" distinct from a general VASP that offers custody services.
The Virtual Assets Service Providers Act, 2022, and its accompanying regulations (Application and Fees Regulation...
The Virtual Assets Service Providers Act, 2022, and its accompanying regulations (Application and Fees Regulations, 2023) are relatively new and represent the current, active regulatory framework.
Ongoing Monitoring: Continuous monitoring of customer relationships and transactions to identify any changes in r...
Ongoing Monitoring: Continuous monitoring of customer relationships and transactions to identify any changes in risk profile or potential matches against updated sanctions lists.
Section 24 (AML/CFT Obligations): This section broadly requires VASPs to comply with AML/CFT laws, regulations, a...
Section 24 (AML/CFT Obligations): This section broadly requires VASPs to comply with AML/CFT laws, regulations, and international best practices, which inherently includes sanctions compliance.
Section 25 (Reporting of Suspicious Transactions): VASPs must report suspicious transactions, including those rel...
Section 25 (Reporting of Suspicious Transactions): VASPs must report suspicious transactions, including those related to sanctions violations, to the FIU.
Other jurisdictions or entities specifically designated on relevant sanctions lists.
Other jurisdictions or entities specifically designated on relevant sanctions lists.
UN Sanctions Lists: For legally binding compliance.
UN Sanctions Lists: For legally binding compliance.
OFAC Sanctions Lists (e.g., SDN List): For critical de facto compliance and to avoid secondary sanctions and main...
OFAC Sanctions Lists (e.g., SDN List): For critical de facto compliance and to avoid secondary sanctions and maintain international banking relationships.
EU Sanctions Lists: For critical de facto compliance due to similar reasons as OFAC.
EU Sanctions Lists: For critical de facto compliance due to similar reasons as OFAC.
Imposing Fines and Penalties: For breaches of regulatory requirements.
Imposing Fines and Penalties: For breaches of regulatory requirements.
Virtual Asset (VA): Defined in the VA Act 2023 (Section 2) as "a digital representation of value that can be digi...
Virtual Asset (VA): Defined in the VA Act 2023 (Section 2) as "a digital representation of value that can be digitally traded or transferred and used for payment or investment purposes but does not include digital representation of fiat currencies, securities and other financial assets that are already covered under other existing laws."
Financial Service Token: The VA Act also defines this as "a virtual asset that is transferable and divisible and ...
Financial Service Token: The VA Act also defines this as "a virtual asset that is transferable and divisible and (a) confers rights similar to those conferred by derivatives or other financial instruments or (b) is used to gain access to a financial service." If a stablecoin represents a share in a fund, a bond, or another regulated financial instrument, it could be classified as a Financial Service Token and potentially fall under existing securities laws in addition to the VA Act.
Payment Token: While not explicitly defined as a distinct category for stablecoins, their primary function as a m...
Payment Token: While not explicitly defined as a distinct category for stablecoins, their primary function as a medium of exchange aligns with the concept of a payment token. However, the regulatory focus is more on the activities surrounding virtual assets rather than the specific token type.
Effective Date: The primary legislation governing this came into force with:
Effective Date: The primary legislation governing this came into force with:
Risk-Based Approach: VASPs are expected to implement a risk-based approach to identify and mitigate ML/FT risks, ...
Risk-Based Approach: VASPs are expected to implement a risk-based approach to identify and mitigate ML/FT risks, which includes screening transactions and parties for sanctions and suspicious activity.
De Facto Ban: The Central Bank of Sudan (CBOS) has repeatedly warned against the use of cryptocurrencies, citing ...
De Facto Ban: The Central Bank of Sudan (CBOS) has repeatedly warned against the use of cryptocurrencies, citing risks such as money laundering, terrorism financing, price volatility, and consumer protection issues. These warnings have effectively created a ban on their use within the formal financial system.
No Licensed VASPs: Due to this stance, there are no licensed or regulated Virtual Asset Service Providers (VASPs)...
No Licensed VASPs: Due to this stance, there are no licensed or regulated Virtual Asset Service Providers (VASPs) operating legally in Sudan. Any entity facilitating crypto transactions would be doing so outside the formal regulatory framework and potentially illegally.
Central Bank of Sudan Regulations and Directives: The CBOS issues various circulars, regulations, and guidelines ...
Central Bank of Sudan Regulations and Directives: The CBOS issues various circulars, regulations, and guidelines that supplement the AML/CFT Law, providing detailed requirements for financial institutions.
Central Bank of Sudan (CBOS):
Central Bank of Sudan (CBOS):
Custodial License Requirements: No licenses are issued for cryptocurrency custody as the activity itself is not f...
Custodial License Requirements: No licenses are issued for cryptocurrency custody as the activity itself is not formally recognized or permitted.
Pending Custody Legislation: There is no publicly known or readily available information about pending legislatio...
Pending Custody Legislation: There is no publicly known or readily available information about pending legislation specifically addressing cryptocurrency custody in Sudan. The focus, where it exists, has primarily been on warnings or prohibitions rather than developing a regulatory framework for virtual assets.
2018 & Beyond: The Central Bank of Sudan has repeatedly warned against cryptocurrency trading. For example, in 20...
2018 & Beyond: The Central Bank of Sudan has repeatedly warned against cryptocurrency trading. For example, in 2018, it reportedly issued a circular prohibiting financial institutions from dealing with cryptocurrencies. This stance has been reiterated in subsequent years.
Entity Targeted: The general public and financial institutions in Sudan (not a specific company or individual in ...
Entity Targeted: The general public and financial institutions in Sudan (not a specific company or individual in a formal "enforcement action").
De Facto Prohibition/Strong Discouragement: While there might not be an explicit blanket ban in the form of a spe...
De Facto Prohibition/Strong Discouragement: While there might not be an explicit blanket ban in the form of a specific law against holding cryptocurrencies, their use for transactions or the operation of crypto-related businesses is highly discouraged and effectively operates in a legal grey area, if not against CBoS directives.
Exchanges (VASP-like activities): There are no specific licenses for cryptocurrency exchanges in Sudan. Any e...
Exchanges (VASP-like activities): There are no specific licenses for cryptocurrency exchanges in Sudan. Any entity attempting to operate such a business would do so without specific regulatory approval, exposing them to significant legal and operational risks, including potential enforcement actions from the CBoS or other financial authorities under existing banking or financial services laws.
Neither: As there is no specific framework, there is no established registration or licensing regime for virt...
Neither: As there is no specific framework, there is no established registration or licensing regime for virtual asset service providers (VASPs) in Sudan.
Bank of Sudan's Stance (Reported): The CBoS has issued numerous warnings against the use of cryptocurrencies. The...
Bank of Sudan's Stance (Reported): The CBoS has issued numerous warnings against the use of cryptocurrencies. These warnings are often reported by local and international news outlets.
General Prohibition/Discouragement: The existing directives from the Central Bank of Sudan broadly discourage or ...
General Prohibition/Discouragement: The existing directives from the Central Bank of Sudan broadly discourage or prohibit all cryptocurrency-related activities due to their unregulated nature and perceived risks. This means the focus is not on classifying which tokens are securities, but rather on preventing or warning against all forms of cryptocurrency.
Discouraged/Prohibited: Any trading would occur on unregulated, likely foreign, platforms. Individuals engaging i...
Discouraged/Prohibited: Any trading would occur on unregulated, likely foreign, platforms. Individuals engaging in such activities would be doing so at their own risk and potentially in contravention of Central Bank directives regarding foreign exchange and financial activities.
Obligation to Register: VASPs must register with the Office for Money Laundering Prevention (UPPD). This is a...
Obligation to Register: VASPs must register with the Office for Money Laundering Prevention (UPPD). This is a registration requirement, not a full prudential licensing regime akin to banks or investment firms, but it entails strict AML/CFT compliance obligations.
Currently (Pre-MiCA): ZPPDFT-2 primarily focuses on AML/CFT compliance, ensuring the identification of asset ow...
Currently (Pre-MiCA): ZPPDFT-2 primarily focuses on AML/CFT compliance, ensuring the identification of asset ownership and preventing illicit finance. It does not explicitly mandate insolvency-remote segregation of client crypto assets from the custodian's own assets in the same way traditional financial regulations (e.g., MiFID II for investment firms, CRD for banks) do.
Definition of Funds/Economic Resources: The relevant EU regulations define "funds" and "economic resources" broad...
Definition of Funds/Economic Resources: The relevant EU regulations define "funds" and "economic resources" broadly, encompassing all forms of assets. With the implementation of the 5th and 6th Anti-Money Laundering Directives (AMLD5/6), virtual assets are unequivocally covered by AML/CFT obligations, and by extension, financial sanctions.
VASP Compliance: The same obligations as for EU sanctions apply. VASPs must screen against the UN Sanctions List ...
VASP Compliance: The same obligations as for EU sanctions apply. VASPs must screen against the UN Sanctions List (which is integrated into the EU Consolidated Sanctions List) and report any matches or suspicions.
Secondary Sanctions: Certain OFAC programs impose "secondary sanctions" on non-US persons for engaging in specifi...
Secondary Sanctions: Certain OFAC programs impose "secondary sanctions" on non-US persons for engaging in specific transactions with sanctioned entities, even without a direct US nexus. This is particularly relevant for entities dealing with countries like Iran or North Korea.
Global Best Practice: Given the global nature of cryptocurrencies, many international VASPs choose to comply with...
Global Best Practice: Given the global nature of cryptocurrencies, many international VASPs choose to comply with OFAC sanctions as a best practice to avoid potential penalties, reputational damage, or loss of access to global financial infrastructure.
VASP Compliance: Global VASPs typically screen against OFAC's Specially Designated Nationals (SDN) and Blocked Pe...
VASP Compliance: Global VASPs typically screen against OFAC's Specially Designated Nationals (SDN) and Blocked Persons List, as well as other relevant OFAC lists (e.g., sectoral sanctions identifications list).
Key National Law: The primary legislation is the Zakon o preprečevanju pranja denarja in financiranja terorizma...
Key National Law: The primary legislation is the Zakon o preprečevanju pranja denarja in financiranja terorizma (ZPPDFT-1) – Act on the Prevention of Money Laundering and Terrorist Financing. This act incorporates the requirements of EU AML Directives and establishes the framework for implementing financial sanctions.
Geographic Restrictions: These are directly derived from the targets of UN and EU sanctions regimes. VASPs must r...
Geographic Restrictions: These are directly derived from the targets of UN and EU sanctions regimes. VASPs must restrict transactions involving sanctioned countries, territories (e.g., Crimea), or regions, as well as any individuals or entities located within or operating from these areas, if they are subject to sanctions. Examples include prohibitions related to Russia, Belarus, North Korea, Iran, Syria, etc.
Credit Institutions: Credit institutions (banks) are exempt from requiring separate MiCA authorization if they is...
Credit Institutions: Credit institutions (banks) are exempt from requiring separate MiCA authorization if they issue stablecoins, but they must notify the competent authority.
Implied Disapproval/Lack of Framework: This means such algorithmic stablecoins do not benefit from the specific s...
Implied Disapproval/Lack of Framework: This means such algorithmic stablecoins do not benefit from the specific stability-focused regulations of MiCA. They would likely fall under the general "other crypto-assets" category within MiCA, subject to white paper requirements and general market conduct rules, but not the stringent prudential and reserve rules. This effectively means MiCA does not provide a regulatory path for pure algorithmic stablecoins to operate within its defined stablecoin categories.
Digital Euro Exploration: The European Central Bank (ECB) is actively exploring the development of a digital Eu...
Digital Euro Exploration: The European Central Bank (ECB) is actively exploring the development of a digital Euro. If and when a digital Euro is introduced, it would serve as a public, central bank-issued complement to private stablecoins and traditional cash, aiming to ensure monetary sovereignty and financial stability.
Impact on Stablecoins: A digital Euro would likely act as a strong alternative to private stablecoins, particular...
Impact on Stablecoins: A digital Euro would likely act as a strong alternative to private stablecoins, particularly EMTs, potentially reducing their appeal by offering a risk-free, central bank-backed digital currency for payments. Slovenia would adopt the digital Euro as part of its participation in the Eurozone.
Consumer Protection: Banka Slovenije and ATVP frequently issue warnings to the public about the high risks associ...
Consumer Protection: Banka Slovenije and ATVP frequently issue warnings to the public about the high risks associated with investing in crypto-assets, emphasizing volatility, lack of regulatory oversight (pre-MiCA), and potential for fraud.
Rationale: FURS considers that profits from the sale of virtual currencies by individuals (who are not engaged in...
Rationale: FURS considers that profits from the sale of virtual currencies by individuals (who are not engaged in a registered business activity) are generally not subject to personal income tax (dohodnina) as they do not fall under any defined category of taxable income (e.g., capital gains, business income, income from other activities).
Exchange of traditional currency for cryptocurrency and vice-versa (and crypto for crypto) is generally EXEMPT from...
Exchange of traditional currency for cryptocurrency and vice-versa (and crypto for crypto) is generally EXEMPT from VAT. This is because virtual currencies are treated as equivalent to traditional currencies in that they are a means of payment and are thus analogous to financial services involving "currency, bank notes and coins used as legal tender."
Declaration of Accounts Held Abroad: This is a crucial requirement. Individuals must report to FURS any foreign b...
Declaration of Accounts Held Abroad: This is a crucial requirement. Individuals must report to FURS any foreign bank accounts, payment accounts, or financial accounts (including accounts on foreign cryptocurrency exchanges) if the balance exceeds a certain threshold (often EUR 10,000 equivalent at any point during the year). This is done via the form "Poročilo o stanju sredstev na računih v tujini" (Report on the status of funds in accounts abroad).
FURS Interpretations and Guidance: FURS has issued several opinions, clarifications, and frequently asked questio...
FURS Interpretations and Guidance: FURS has issued several opinions, clarifications, and frequently asked questions (FAQs) over the years to guide taxpayers on how existing laws apply to virtual assets. These interpretations serve as the primary source of crypto-specific tax guidance in Slovenia. They reflect FURS's official position on various scenarios.
However, the specific and comprehensive implementation of the FATF Travel Rule for crypto assets, as defined by Reg...
However, the specific and comprehensive implementation of the FATF Travel Rule for crypto assets, as defined by Regulation (EU) 2023/1113, becomes applicable much later: 30 December 2024. This is the key date for the full Travel Rule requirements for crypto assets.
Units in collective investment undertakings: Tokens representing interests in a fund or scheme that pools investo...
Units in collective investment undertakings: Tokens representing interests in a fund or scheme that pools investor capital with a view to investing it in accordance with a defined investment policy for the benefit of those investors.
E-Money Tokens (EMT): Tokens whose main purpose is to function as electronic money as defined in the E-Money Dire...
E-Money Tokens (EMT): Tokens whose main purpose is to function as electronic money as defined in the E-Money Directive 2009/110/EC. (Regulated under MiCA).
General Enforcement Powers: The NBS has powers to:
General Enforcement Powers: The NBS has powers to:
MiCA acknowledges the potential for Central Bank Digital Currencies (CBDCs) and their interaction with private stable...
MiCA acknowledges the potential for Central Bank Digital Currencies (CBDCs) and their interaction with private stablecoins.
The European Central Bank (ECB) is actively exploring a digital euro as a potential CBDC for the Eurozone. Wh...
The European Central Bank (ECB) is actively exploring a digital euro as a potential CBDC for the Eurozone. While no definitive decision has been made for its issuance, the framework for private stablecoins (especially EMTs) is designed with a potential digital euro in mind.
The key amendments to Slovak AML law that brought virtual asset service providers under the AML/CFT regime, including...
The key amendments to Slovak AML law that brought virtual asset service providers under the AML/CFT regime, including Travel Rule-like obligations, came into effect on 1 March 2020. This was through Act No. 397/2019 Coll., which amended the primary AML Act.
Fines: Significant administrative fines can be imposed on both legal entities (VASPs) and responsible individuals...
Fines: Significant administrative fines can be imposed on both legal entities (VASPs) and responsible individuals. Fines for legal entities can range from thousands to millions of Euros, depending on the severity and recurrence of the breach.
Monitor for Updates: Stay informed about any new legislation, regulations, or directives issued by the Sierra Leo...
Monitor for Updates: Stay informed about any new legislation, regulations, or directives issued by the Sierra Leonean authorities concerning virtual assets.
Anti-Money Laundering and Combating of Terrorist Financing Act, 2012 (or latest iteration): This act and its subs...
Anti-Money Laundering and Combating of Terrorist Financing Act, 2012 (or latest iteration): This act and its subsequent amendments would generally apply to financial institutions and designated non-financial businesses and professions. If virtual asset service providers (VASPs) are eventually classified under this act, they would be subject to customer due diligence (CDD), record-keeping, and suspicious transaction reporting (STR) obligations.
Compliance Requirement: UN Security Council resolutions imposing sanctions are legally binding on all UN member s...
Compliance Requirement: UN Security Council resolutions imposing sanctions are legally binding on all UN member states, including Sierra Leone. Sierra Leone incorporates these obligations into its domestic law, primarily through its anti-money laundering and combating the financing of terrorism framework.
Focus: UN sanctions programs typically target:
Focus: UN sanctions programs typically target:
VASP Obligations: Any VASP operating in or from Sierra Leone must screen its customers and transactions against t...
VASP Obligations: Any VASP operating in or from Sierra Leone must screen its customers and transactions against the UN Consolidated Sanctions List and specific UN Security Council Committee Sanctions Lists. Assets of listed individuals/entities must be frozen without delay, and any attempt to circumvent these measures must be reported.
Compliance Requirement: While OFAC sanctions primarily target "U.S. persons" (U.S. citizens, permanent residents,...
Compliance Requirement: While OFAC sanctions primarily target "U.S. persons" (U.S. citizens, permanent residents, entities organized under U.S. law, and anyone within the United States), their extraterritorial reach is significant.
VASP Obligations: VASPs must screen all customers and transactions against OFAC's Specially Designated Nationals ...
VASP Obligations: VASPs must screen all customers and transactions against OFAC's Specially Designated Nationals and Blocked Persons (SDN) List and other relevant sanctions lists. They must block (freeze) the assets of SDNs and report such blocking to OFAC. Transactions involving sanctioned jurisdictions or entities are prohibited.
Compliance Requirement: Similar to OFAC, EU sanctions primarily bind EU persons and entities. However, any VASP i...
Compliance Requirement: Similar to OFAC, EU sanctions primarily bind EU persons and entities. However, any VASP in Sierra Leone that has a nexus to the EU (e.g., serving EU customers, having an EU presence, or dealing with EU-based financial institutions) should comply with EU sanctions.
VASP Obligations: VASPs should screen customers and transactions against the EU Consolidated Financial Sanctions ...
VASP Obligations: VASPs should screen customers and transactions against the EU Consolidated Financial Sanctions List. Assets of listed individuals/entities must be frozen, and dealings with them are prohibited.
The Anti-Money Laundering and Combating of Financing of Terrorism Act, 2018: While an online copy with a direct, ...
The Anti-Money Laundering and Combating of Financing of Terrorism Act, 2018: While an online copy with a direct, stable URL is not readily available through general government searches, this Act is the primary domestic legislation for AML/CFT in Sierra Leone. It would be accessible via legal databases or directly from the Bank of Sierra Leone (BSL) or the Financial Intelligence Unit – Sierra Leone (FIU-SL).
Financial Intelligence Unit – Sierra Leone (FIU-SL): http://www.fiu.gov.sl/ (The FIU-SL is the supervisory body f...
Financial Intelligence Unit – Sierra Leone (FIU-SL): http://www.fiu.gov.sl/ (The FIU-SL is the supervisory body for AML/CFT compliance and would issue guidance related to sanctions.)
Monetary Fines: Substantial financial penalties for institutions and individuals.
Monetary Fines: Substantial financial penalties for institutions and individuals.
Imprisonment: Individuals found guilty of offenses, including facilitating sanctions evasion or money laundering,...
Imprisonment: Individuals found guilty of offenses, including facilitating sanctions evasion or money laundering, can face significant jail terms.
Reputational Damage: Significant harm to an entity's reputation, potentially leading to loss of customers, bankin...
Reputational Damage: Significant harm to an entity's reputation, potentially leading to loss of customers, banking relationships, and operational difficulties.
Secondary Sanctions (for non-U.S./EU entities): A VASP in Sierra Leone that violates U.S. or EU sanctions could f...
Secondary Sanctions (for non-U.S./EU entities): A VASP in Sierra Leone that violates U.S. or EU sanctions could face penalties from those jurisdictions, even if not directly present there, potentially losing access to those markets and financial systems.
Partial/Cautionary/Warning-Based: Sierra Leone does not have a comprehensive regulatory framework for virtual ass...
Partial/Cautionary/Warning-Based: Sierra Leone does not have a comprehensive regulatory framework for virtual assets. Instead, the approach is primarily characterized by warnings from the central bank, emphasizing the risks associated with cryptocurrencies and stating they are not legal tender. There is no official recognition, licensing, or specific regulation for crypto service providers.
Bank of Sierra Leone (BSL): As the central bank, the BSL is the primary institution that has issued official stat...
Bank of Sierra Leone (BSL): As the central bank, the BSL is the primary institution that has issued official statements and warnings regarding cryptocurrencies due to their implications for monetary policy, financial stability, and consumer protection.
Public Notice on Virtual Currencies/Crypto Assets by the Bank of Sierra Leone (Dated 12th February 2021):
Public Notice on Virtual Currencies/Crypto Assets by the Bank of Sierra Leone (Dated 12th February 2021):
Not explicitly adopted or fully implemented through specific legislation targeting VASPs and the Travel Rule.
Not explicitly adopted or fully implemented through specific legislation targeting VASPs and the Travel Rule.
While Sierra Leone has a foundational AML/CFT law, the Anti-Money Laundering and Combating of Terrorist Financing A...
While Sierra Leone has a foundational AML/CFT law, the Anti-Money Laundering and Combating of Terrorist Financing Act, 2019, this act does not explicitly define "Virtual Assets" or "Virtual Asset Service Providers" in a way that would trigger the specific requirements of the Travel Rule.
GIABA's Mutual Evaluation Reports and subsequent follow-up reports on Sierra Leone have consistently highlighted defi...
GIABA's Mutual Evaluation Reports and subsequent follow-up reports on Sierra Leone have consistently highlighted deficiencies in addressing new technologies and products, including virtual assets, indicating a lack of comprehensive regulatory and supervisory framework for VASPs. As of the latest public reports, Recommendation 15 (New Technologies) is typically rated as "Partially Compliant" or "Non-Compliant" for Sierra Leone, specifically due to the absence of a legal and regulatory framework to supervise VASPs and implement the Travel Rule.
There is no specific effective date for the FATF Travel Rule in Sierra Leone because dedicated legislation for it...
There is no specific effective date for the FATF Travel Rule in Sierra Leone because dedicated legislation for it has not been enacted.
No specific categories of VASPs are explicitly covered under a VASP-specific regulatory framework in Sierra Leone.
No specific categories of VASPs are explicitly covered under a VASP-specific regulatory framework in Sierra Leone.
In the absence of specific VASP legislation, entities dealing with virtual assets might be subject to general AML/CFT...
In the absence of specific VASP legislation, entities dealing with virtual assets might be subject to general AML/CFT obligations if their activities are broadly interpreted as financial services under the Anti-Money Laundering and Combating of Terrorist Financing Act, 2019, or if the Bank of Sierra Leone issues specific warnings or directives. However, this general coverage does not equate to the explicit VASP definition and Travel Rule application recommended by FATF.
However, if an entity operating in Sierra Leone facilitates illicit financial activities (e.g., money laundering, ter...
However, if an entity operating in Sierra Leone facilitates illicit financial activities (e.g., money laundering, terrorist financing) using virtual assets, they would be subject to the penalties outlined in the Anti-Money Laundering and Combating of Terrorist Financing Act, 2019, and potentially other criminal statutes. These penalties can include significant fines and imprisonment.
Bank of Sierra Leone (BSL) Statements/Circulars: The BSL, as the central bank, might issue warnings or general gu...
Bank of Sierra Leone (BSL) Statements/Circulars: The BSL, as the central bank, might issue warnings or general guidance regarding cryptocurrencies. While not full regulation, these indicate the regulatory stance.
Banca Centrale della Repubblica di San Marino (BCSM) - Central Bank of the Republic of San Marino
Banca Centrale della Repubblica di San Marino (BCSM) - Central Bank of the Republic of San Marino
Banca Centrale della Repubblica di San Marino (BCRA) - Normativa (Regulations) Page: This is the central hub wher...
Banca Centrale della Repubblica di San Marino (BCRA) - Normativa (Regulations) Page: This is the central hub where all laws and circulars are typically published or linked.
Obligations: VASPs must identify and freeze assets belonging to, or controlled by, designated individuals and ent...
Obligations: VASPs must identify and freeze assets belonging to, or controlled by, designated individuals and entities on EU sanctions lists. They are also prohibited from making funds or economic resources available to such listed parties. This includes all forms of virtual assets and related services.
Extraterritorial Reach: OFAC sanctions, while U.S. law, have a significant extraterritorial effect, particularly ...
Extraterritorial Reach: OFAC sanctions, while U.S. law, have a significant extraterritorial effect, particularly on financial institutions and entities dealing with U.S. persons, the U.S. financial system, or transactions denominated in U.S. dollars.
Obligations: Prudent VASPs will screen against OFAC's Specially Designated Nationals (SDN) List and other relevan...
Obligations: Prudent VASPs will screen against OFAC's Specially Designated Nationals (SDN) List and other relevant lists (e.g., Sectoral Sanctions Identifications List) and implement controls to prevent dealings with sanctioned persons or jurisdictions.
Sanctions List Screening: Regularly screen all customers, beneficial owners, and counterparties against relevant ...
Sanctions List Screening: Regularly screen all customers, beneficial owners, and counterparties against relevant international sanctions lists, including:
Technology Solutions: Utilizing automated sanctions screening software is best practice for efficient and accurat...
Technology Solutions: Utilizing automated sanctions screening software is best practice for efficient and accurate screening of large volumes of data and transactions, including blockchain addresses.
Criminal Penalties: Individuals and legal representatives of VASPs found to be in breach of sanctions regulations...
Criminal Penalties: Individuals and legal representatives of VASPs found to be in breach of sanctions regulations can face fines and imprisonment. Law No. 182/2004 provides for criminal sanctions for AML/CTF offenses, which include failures related to sanctions compliance.
Administrative Penalties: The BCSM and AIF can impose administrative fines, operational restrictions, suspension ...
Administrative Penalties: The BCSM and AIF can impose administrative fines, operational restrictions, suspension or revocation of licenses, and public reprimands on VASPs that fail to comply with their obligations.
Secondary Sanctions Risk: As mentioned, non-compliance with OFAC sanctions, even for non-U.S. entities, can resul...
Secondary Sanctions Risk: As mentioned, non-compliance with OFAC sanctions, even for non-U.S. entities, can result in being cut off from the U.S. financial system or facing other punitive measures.
EU Consolidated List: This list amalgamates all persons, groups, and entities subject to financial sanctions unde...
EU Consolidated List: This list amalgamates all persons, groups, and entities subject to financial sanctions under various EU restrictive measures.
BCSM General Regulatory Framework for DLT: The BCSM website is the primary source for updated circulars and regul...
BCSM General Regulatory Framework for DLT: The BCSM website is the primary source for updated circulars and regulations regarding DLT assets and Qualified Operators.
Regulatory Scrutiny: Any proposed issuance of an algorithmic stablecoin would face intense scrutiny from the BCRS...
Regulatory Scrutiny: Any proposed issuance of an algorithmic stablecoin would face intense scrutiny from the BCRSM due to inherent volatility and systemic risks. It is unlikely that such tokens would be authorized for public offering as a regulated financial instrument without significant policy development.
Project Titan and San Marino Token (SMT): San Marino initiated "Project Titan" in 2019 to explore a DLT-based fin...
Project Titan and San Marino Token (SMT): San Marino initiated "Project Titan" in 2019 to explore a DLT-based financial ecosystem. This included a plan for a "San Marino Token (SMT)," which was envisioned as a utility token convertible into fiat, with a portion of the revenue going to the state. While not a direct CBDC (as it wasn't a central bank liability), it showed the state's interest in DLT-based digital currencies and could be seen as a precursor or a private-sector stablecoin initiative with government backing.
Enabling Framework: The DLT Law and the BCRSM's decrees provide a robust legal and regulatory sandbox-like enviro...
Enabling Framework: The DLT Law and the BCRSM's decrees provide a robust legal and regulatory sandbox-like environment that could facilitate the development or interaction with a future Central Bank Digital Currency (CBDC). The existing infrastructure for licensing DLT operators, defining financial instruments on DLT, and strong AML/CFT controls would be highly relevant for any CBDC implementation.
No Formal CBDC Launched: As of now, San Marino has not launched a formal, fully-fledged central bank-issued CBDC....
No Formal CBDC Launched: As of now, San Marino has not launched a formal, fully-fledged central bank-issued CBDC. However, its innovative DLT framework positions it as a potential early adopter or experimenter in the CBDC space, allowing for seamless integration if such a decision is made in the future.
Banca Centrale della Repubblica di San Marino (BCRSM) - The Central Bank of the Republic of San Marino. It is the...
Banca Centrale della Repubblica di San Marino (BCRSM) - The Central Bank of the Republic of San Marino. It is the primary financial regulator responsible for licensing, supervision, and ongoing oversight of virtual asset service providers.
Extensive Reporting: Businesses operating in the crypto space are subject to significant reporting requirements d...
Extensive Reporting: Businesses operating in the crypto space are subject to significant reporting requirements due to the regulatory framework established by Delegated Decree No. 36/2019 and general financial regulations.
Licensing and Supervision: Entities engaged in crypto-asset services (e.g., exchanges, custodians, issuers) must ...
Licensing and Supervision: Entities engaged in crypto-asset services (e.g., exchanges, custodians, issuers) must obtain a license from the Central Bank of San Marino (BCSM) and are subject to its ongoing supervision.
Explanation: Since cryptocurrencies are not officially recognized or regulated as financial assets by the BCEAO o...
Explanation: Since cryptocurrencies are not officially recognized or regulated as financial assets by the BCEAO or Senegalese authorities, there is no licensing regime for entities providing custody services for these assets. Any entity providing such services would operate without specific regulatory oversight in this domain.
Explanation: In the absence of a defined regulatory framework for crypto custody, there are no legal requirements...
Explanation: In the absence of a defined regulatory framework for crypto custody, there are no legal requirements for how client digital assets must be segregated from the custodian's own assets. This lack of regulation presents significant risks to clients in the event of a custodian's insolvency or mismanagement.
Explanation: As with other aspects, without a formal licensing and regulatory framework, there are no mandates fo...
Explanation: As with other aspects, without a formal licensing and regulatory framework, there are no mandates for custodians to carry insurance or bonds to protect client assets against theft, loss, or operational failures.
Explanation: The concept of a "qualified custodian" typically arises within mature regulatory frameworks (like th...
Explanation: The concept of a "qualified custodian" typically arises within mature regulatory frameworks (like those in the U.S. under SEC rules). Since no such framework exists for digital assets in Senegal, this definition is not applicable.
IMF and World Bank Reports: These international bodies often report on the regulatory positions of central banks ...
IMF and World Bank Reports: These international bodies often report on the regulatory positions of central banks in various regions, including the BCEAO. They frequently cite the BCEAO's warnings.
Under Loi 2018-03, Article 18: Obliged entities must establish internal control procedures, including systems for...
Under Loi 2018-03, Article 18: Obliged entities must establish internal control procedures, including systems for risk management and for detecting and reporting suspicious transactions. This implicitly requires screening customers and transactions against relevant sanctions lists.
Administrative Penalties (Articles 50-53): CENTIF or the relevant supervisory authority can impose warnings, repr...
Administrative Penalties (Articles 50-53): CENTIF or the relevant supervisory authority can impose warnings, reprimands, fines, and even temporary or permanent prohibition from exercising certain professional activities. Fines can be substantial, calculated based on the gravity of the breach and the entity's turnover.
No specific "crypto-specific" sanctions lists exist in Senegal. Sanctions lists are typically asset-agnostic and ...
No specific "crypto-specific" sanctions lists exist in Senegal. Sanctions lists are typically asset-agnostic and target individuals, entities, or regimes, regardless of the asset class (fiat or crypto).
Senegal's primary obligation is to implement the UN Consolidated Sanctions List.
Senegal's primary obligation is to implement the UN Consolidated Sanctions List.
The CENTIF of Senegal (Cellule Nationale de Traitement des Informations Financières) may, in certain circumstance...
The CENTIF of Senegal (Cellule Nationale de Traitement des Informations Financières) may, in certain circumstances, issue internal alerts or lists related to individuals or entities suspected of ML/TF within Senegal, which obliged entities would be expected to monitor. However, these are not typically public "sanctions lists" in the international sense but rather internal intelligence for enforcement.
Intermediary Involvement: The issuance may require the involvement of authorized financial intermediaries (e.g., ...
Intermediary Involvement: The issuance may require the involvement of authorized financial intermediaries (e.g., investment banks, brokerage firms) approved by CREPMF.
Preventative Warnings: CREPMF (and BCEAO) has consistently issued warnings to the public about the risks associat...
Preventative Warnings: CREPMF (and BCEAO) has consistently issued warnings to the public about the risks associated with investing in unregulated cryptocurrencies and ICOs. Communication N° 001/2019 serves as a clear statement of regulatory intent and a warning against unauthorized offerings.
Default as Unregulated Crypto-Assets: In practice, most stablecoins (especially those issued by entities not lice...
Default as Unregulated Crypto-Assets: In practice, most stablecoins (especially those issued by entities not licensed by the BCEAO or not fully compliant with e-money regulations) are considered unregulated crypto-assets. The BCEAO has explicitly stated that such assets are not recognized as currencies or financial instruments and carry significant risks.
For E-money (if applicable): BCEAO regulations for electronic money issuers mandate 100% backing of all elect...
For E-money (if applicable): BCEAO regulations for electronic money issuers mandate 100% backing of all electronic money liabilities. This means that for every unit of e-money issued, the issuer must hold an equivalent value in liquid, low-risk assets (typically funds deposited in a segregated account at a financial institution authorized by the BCEAO).
The BCEAO is actively exploring the feasibility of a Central Bank Digital Currency (CBDC) for the WAEMU region, o...
The BCEAO is actively exploring the feasibility of a Central Bank Digital Currency (CBDC) for the WAEMU region, often referred to as the "eCFA." This initiative is in the research and design phase.
Adopted: Yes, through the BCEAO regulatory framework.
Adopted: Yes, through the BCEAO regulatory framework.
Administrative Sanctions: Imposed by the BCEAO, such as:
Administrative Sanctions: Imposed by the BCEAO, such as:
Ongoing Efforts in AML/CFT: Somalia is actively working with international partners, including the Financial Acti...
Ongoing Efforts in AML/CFT: Somalia is actively working with international partners, including the Financial Action Task Force (FATF), to improve its AML/CFT regime. While this indirectly creates an environment where new financial technologies like crypto would eventually need oversight, it hasn't yet led to specific crypto enforcement actions.
Compliance Requirement for VASPs: U.S. persons and VASPs subject to U.S. jurisdiction must screen all their custo...
Compliance Requirement for VASPs: U.S. persons and VASPs subject to U.S. jurisdiction must screen all their customers and transactions against OFAC's Specially Designated Nationals and Blocked Persons (SDN) List and other OFAC sanctions lists. Any property or interests in property of designated persons must be blocked, and U.S. persons are generally prohibited from engaging in transactions with them.
Compliance Requirement for VASPs: VASPs subject to EU jurisdiction must screen their customers and transactions a...
Compliance Requirement for VASPs: VASPs subject to EU jurisdiction must screen their customers and transactions against the EU Consolidated Financial Sanctions List. Any match requires immediate asset freezing and reporting to national competent authorities.
Significant Fines: Both civil and criminal penalties can run into millions or even billions of dollars, depending...
Significant Fines: Both civil and criminal penalties can run into millions or even billions of dollars, depending on the jurisdiction and the scale of the violation.
Reputational Damage: Sanctions violations can lead to severe reputational harm, loss of customer trust, and busin...
Reputational Damage: Sanctions violations can lead to severe reputational harm, loss of customer trust, and business opportunities.
OFAC Penalties: U.S. sanctions violations can lead to civil penalties up to hundreds of thousands of dollars per ...
OFAC Penalties: U.S. sanctions violations can lead to civil penalties up to hundreds of thousands of dollars per violation, and criminal penalties up to $20 million and 30 years imprisonment.
EU Penalties: Penalties vary by Member State but can include significant fines and imprisonment, aligned with nat...
EU Penalties: Penalties vary by Member State but can include significant fines and imprisonment, aligned with national laws implementing EU regulations.
Comprehensive screening against global sanctions lists (UN, OFAC, EU).
Comprehensive screening against global sanctions lists (UN, OFAC, EU).
Ongoing monitoring for changes in sanctions lists and customer behavior.
Ongoing monitoring for changes in sanctions lists and customer behavior.
None specifically for crypto custody. There is no specific licensing regime in Suriname for companies providing c...
None specifically for crypto custody. There is no specific licensing regime in Suriname for companies providing cryptocurrency or digital asset custody services.
Suriname's existing financial services licensing laws (e.g., for banks, money transfer businesses) do not explicitly ...
Suriname's existing financial services licensing laws (e.g., for banks, money transfer businesses) do not explicitly cover or define virtual asset custody as a regulated activity.
Regulatory Reference (Indirect): The FATF Mutual Evaluation Report for Suriname (published in 2020 and subsequent...
Regulatory Reference (Indirect): The FATF Mutual Evaluation Report for Suriname (published in 2020 and subsequent follow-up reports) indicates that Recommendation 15 (which addresses Virtual Assets and Virtual Asset Service Providers) has significant deficiencies. Suriname has been rated as "Non-Compliant" or "Partially Compliant" with this recommendation, specifically noting that there is no legal or regulatory framework for the licensing, registration, or supervision of VASPs for AML/CFT purposes.
No specific rules. Given the absence of a dedicated regulatory framework for crypto custodians, there are no expl...
No specific rules. Given the absence of a dedicated regulatory framework for crypto custodians, there are no explicit mandates or guidelines requiring the segregation of client digital assets from the custodian's own assets.
No specific definition. Suriname's existing laws do not define what constitutes a "qualified custodian" in the co...
No specific definition. Suriname's existing laws do not define what constitutes a "qualified custodian" in the context of digital assets.
Centrale Bank van Suriname (CBvS): The central bank, responsible for monetary policy, financial stability, and su...
Centrale Bank van Suriname (CBvS): The central bank, responsible for monetary policy, financial stability, and supervision of financial institutions. It has issued warnings regarding cryptocurrencies.
Centrale Bank van Suriname Official Statements: The CBvS periodically issues press releases and statements regard...
Centrale Bank van Suriname Official Statements: The CBvS periodically issues press releases and statements regarding financial sector developments, including warnings about unregulated financial products like cryptocurrencies. Searching their official website (www.cbvs.sr) would show general advisories, but not enforcement actions.
FATF Reports: The FATF evaluates countries' AML/CFT frameworks, including for virtual assets. Suriname's evaluati...
FATF Reports: The FATF evaluates countries' AML/CFT frameworks, including for virtual assets. Suriname's evaluations discuss its legal framework development but not individual enforcement actions.
Centrale Bank van Suriname (CBS): The central bank is the primary financial regulator in Suriname and has issued ...
Centrale Bank van Suriname (CBS): The central bank is the primary financial regulator in Suriname and has issued official statements regarding cryptocurrencies.
There are no specific licenses or permits issued by the CBS or any other Surinamese authority explicitly for operatin...
There are no specific licenses or permits issued by the CBS or any other Surinamese authority explicitly for operating a crypto exchange, providing crypto custody, or processing crypto payments as distinct from traditional financial services.
However, this does not imply a "free pass." If an entity's operations begin to resemble traditional financial ser...
However, this does not imply a "free pass." If an entity's operations begin to resemble traditional financial services (e.g., taking deposits, issuing financial instruments, providing lending services that involve fiat currency or carry financial risk) it could potentially fall under existing financial services laws and require traditional banking, money transfer, or investment licenses from the CBS. This would be determined on a case-by-case basis by the CBS.
Obligation: As a UN member state, Suriname is legally bound to implement sanctions resolutions passed by the UN S...
Obligation: As a UN member state, Suriname is legally bound to implement sanctions resolutions passed by the UN Security Council. These resolutions target individuals, entities, and countries involved in terrorism, proliferation of weapons of mass destruction, and other threats to international peace and security.
Implementation in Suriname: The Government of Suriname, through its financial regulators (primarily the Centrale ...
Implementation in Suriname: The Government of Suriname, through its financial regulators (primarily the Centrale Bank van Suriname - CBvS) and its Financial Intelligence Unit (FIU-S), is responsible for circulating UN sanctions lists (e.g., the UN Security Council Consolidated List) and ensuring financial institutions (which would include VASPs if regulated) comply.
VASP Requirements: VASPs operating in or from Suriname, or dealing with Surinamese customers, must screen all the...
VASP Requirements: VASPs operating in or from Suriname, or dealing with Surinamese customers, must screen all their customers (KYC/CDD) and transactions against the UN sanctions lists. If a match is found, assets must be frozen, and a report made to the FIU-S.
Extraterritorial Reach: The U.S. Office of Foreign Assets Control (OFAC) sanctions primarily apply to "U.S. perso...
Extraterritorial Reach: The U.S. Office of Foreign Assets Control (OFAC) sanctions primarily apply to "U.S. persons" (U.S. citizens, permanent residents, entities organized under U.S. law, and persons within the U.S.). However, OFAC sanctions can have significant extraterritorial effects, especially through secondary sanctions and when transactions involve the U.S. financial system or U.S.-origin technology.
VASP Requirements: VASPs must screen customers and transactions against OFAC's Specially Designated Nationals and...
VASP Requirements: VASPs must screen customers and transactions against OFAC's Specially Designated Nationals and Blocked Persons (SDN) List and other sanctions lists. They should also be aware of OFAC's guidance specifically addressing virtual currency.
Applicability: EU sanctions apply to all EU persons, entities, and anyone operating within the EU's jurisdiction....
Applicability: EU sanctions apply to all EU persons, entities, and anyone operating within the EU's jurisdiction. While Suriname is not an EU member, VASPs in Suriname that have a nexus with the EU (e.g., European ownership, serving EU customers, using EU-based service providers, or transacting with EU-sanctioned individuals/entities) could fall under the scope of EU sanctions.
VASP Requirements: Similar to OFAC, VASPs with an EU nexus must screen against EU sanctions lists, freeze assets,...
VASP Requirements: Similar to OFAC, VASPs with an EU nexus must screen against EU sanctions lists, freeze assets, and report to relevant authorities if matches are found.
The CBvS is the central bank and primary financial regulator in Suriname. While it has issued warnings about the risk...
The CBvS is the central bank and primary financial regulator in Suriname. While it has issued warnings about the risks of cryptocurrencies, comprehensive specific regulations for VASPs are still under development or not yet fully enacted. However, any financial activity, including those involving virtual assets, is expected to adhere to general AML/CFT principles.
Role in Sanctions: The FIU-S would be the primary recipient of reports regarding suspected sanctions violations i...
Role in Sanctions: The FIU-S would be the primary recipient of reports regarding suspected sanctions violations involving virtual assets, once a clear reporting mechanism for VASPs is established. It also disseminates UN sanctions lists domestically.
FATF Recommendations: Suriname, as a jurisdiction subject to FATF assessments, is expected to implement FATF Reco...
FATF Recommendations: Suriname, as a jurisdiction subject to FATF assessments, is expected to implement FATF Recommendation 15 (New Technologies), which requires countries to regulate and supervise VASPs for AML/CFT purposes, including sanctions compliance.
Sanctions Screening: Screen all customers and counterparties (where identifiable), as well as ongoing transaction...
Sanctions Screening: Screen all customers and counterparties (where identifiable), as well as ongoing transactions, against:
Adverse Media Screening: Check for any news or reports linking customers to criminal activity or sanctions evasion.
Adverse Media Screening: Check for any news or reports linking customers to criminal activity or sanctions evasion.
Ongoing Monitoring: Continuously monitor customer activity and re-screen against updated sanctions lists.
Ongoing Monitoring: Continuously monitor customer activity and re-screen against updated sanctions lists.
Financial Penalties: Substantial fines for individuals and legal entities.
Financial Penalties: Substantial fines for individuals and legal entities.
Loss of License/Operating Ability: If a regulatory framework for VASPs is established, non-compliance would likel...
Loss of License/Operating Ability: If a regulatory framework for VASPs is established, non-compliance would likely lead to license revocation.
International Penalties: If OFAC or EU sanctions are violated, U.S. or EU authorities can impose their own substa...
International Penalties: If OFAC or EU sanctions are violated, U.S. or EU authorities can impose their own substantial fines, designate the VASP or individuals on their sanctions lists, and block access to their financial systems.
Wet Toezicht Bank- en Kredietwezen 1993 (Banking and Credit Supervision Act 1993): This is the foundational act f...
Wet Toezicht Bank- en Kredietwezen 1993 (Banking and Credit Supervision Act 1993): This is the foundational act for financial institutions, though it doesn't explicitly mention cryptocurrencies. However, if an entity issuing or dealing with tokens is deemed to be performing banking or credit-related activities, this act would apply.
Warnings against Unlicensed Activities: While not directly crypto-specific, the CBvS has historically acted again...
Warnings against Unlicensed Activities: While not directly crypto-specific, the CBvS has historically acted against entities conducting financial services without proper licenses. If a crypto offering were deemed to fall under existing securities or financial services laws, an unlicensed operation would be subject to enforcement action.