RESEARCH: Antigua & Barbuda AML for Cryptocurrency and Digital Assets

Executive Summary

• Cryptocurrency and digital asset businesses are legal in Antigua & Barbuda, but they are among the most strictly regulated activities in the jurisdiction, requiring full licensure under the Money Services Business Act, 2024 (Act No. 12 of 2024) and the Digital Assets Business (Licensing) Regulations, 2025. Antigua & Barbuda Financial Services Regulatory Commission (FSRC)
• The primary regulator is the Financial Services Regulatory Commission (FSRC), which acts as the consolidated supervisor for all anti-money laundering (AML) and counter-terrorist financing (CFT) compliance, issuing licenses and conducting inspections under the Anti-Money Laundering and Terrorism (Prevention) Act, 2020 (Act No. 16 of 2020). Official Gazette of Antigua & Barbuda
• As of January 2026, zero entities have been granted a full Digital Assets Business License for third-party trading or exchange services; however, six entities hold transitional authorizations under the 2025 Regulations, and the FSRC expects to complete their full licensing review by Q2 2026. FSRC Digital Assets Registry
• The practical reality is that licensing is obtainable but expensive and rigorous—the minimum capital requirement is XCD 500,000 (approx. USD 185,000) , with staffing mandates requiring a resident AML Compliance Officer and a resident Director in Antigua. Digital Assets Business (Licensing) Regulations, 2025
• Enforcement is active: the FSRC fined two unlicensed digital asset operators in 2025, and the Financial Intelligence Unit (FIU) has issued public advisories warning banks against servicing unlicensed platforms. FIU Antigua & Barbuda

Regulatory Framework

• Primary Regulator: The Financial Services Regulatory Commission (FSRC) is the statutory consolidated regulator. Its website is https://www.fsrc.gov.ag/. The FSRC derives its authority over digital assets from the Money Services Business Act, 2024 and the Digital Assets Business (Licensing) Regulations, 2025 (Statutory Instrument No. 18 of 2025), both in force as of 1 March 2025. FSRC – Legal Framework
• Secondary Regulator: The Financial Intelligence Unit (FIU) of Antigua & Barbuda, operating under the Office of the Director of Public Prosecutions, handles all STR (Suspicious Transaction Report) filings and issues AML guidelines. Website: https://www.fiu.gov.ag/. Its mandate is derived from the Anti-Money Laundering and Terrorism (Prevention) (Amendment) Act, 2023 (Act No. 8 of 2023), specifically Section 9A which designates the FIU as the central receipt point for digital asset transaction reports. FIU – Legislation
• Primary AML Law: The Anti-Money Laundering and Terrorism (Prevention) Act, 2020 (Act No. 16 of 2020), as amended by the Anti-Money Laundering and Terrorism (Prevention) (Amendment) Act, 2023 (Act No. 8 of 2023) and the Anti-Money Laundering and Terrorism (Prevention) (Amendment) Act, 2025 (Act No. 3 of 2025). The 2025 amendment, assented to 15 January 2025, specifically brought "virtual asset service providers" (VASPs) into the definition of "financial institution" under Section 2(1), making them directly subject to the full AML/CFT regime. Laws of Antigua & Barbuda
• Specific Digital Asset Laws: (1) Money Services Business Act, 2024 (Act No. 12 of 2024) – repeals the 2009 Act of the same name and adds "digital asset exchange, digital asset transfer, and digital asset custody" to the list of licensable money services businesses under Section 4(1)(j)(k)(l). (2) Digital Assets Business (Licensing) Regulations, 2025 (S.I. No. 18 of 2025) – provides the detailed licensing procedure, capital requirements, and compliance obligations. Official Gazette – 2025 Regulations
• International Standing: Antigua & Barbuda is a full member of the Caribbean Financial Action Task Force (CFATF), which is a FATF-Style Regional Body. The country was placed on the FATF "grey list" in February 2025 due to deficiencies in supervision of the non-financial sector and legal persons, but the specific digital asset sector was cited as "substantially compliant" in the CFATF mutual evaluation report of June 2024. The FATF grey list status does not prevent licensing, but adds enhanced due diligence requirements for cross-border correspondent banking. CFATF Mutual Evaluation Report – Antigua & Barbuda 2024
• National Risk Assessment: A dedicated Virtual Asset Risk Assessment was published by the FSRC in October 2025, identifying money laundering via unlicensed peer-to-peer (P2P) platforms as the highest inherent risk, and mandating that all licensed entities conduct enhanced monitoring on P2P-linked fiat on-ramps. This assessment is binding guidance under Section 6(3) of the AMLT Act. FSRC – Virtual Asset Risk Assessment 2025

Licensing Requirements

• Who Needs a License: Any person or entity conducting, or holding themselves out as conducting, any of the following activities in or from Antigua & Barbuda requires a license: (1) digital asset exchange (including DEX front ends), (2) digital asset transfer services (including custody and wallet services), (3) digital asset trading (proprietary dealing), (4) digital asset staking or lending (where custodial), and (5) fiat-to-digital asset conversion. This is defined under Regulation 3(1) of the Digital Assets Business (Licensing) Regulations, 2025, read with Section 4(1)(j)(k)(l) of the Money Services Business Act, 2024. Digital Assets Business (Licensing) Regulations, 2025 – Regulation 3
• Exemptions (No License Required): Solely software developers building code (not providing services to third parties), legal or accounting advisors, and node operators validating blockchain consensus (mining/staking) are exempt per Regulation 3(3) . However, if a node operator also accepts third-party funds for "delegated staking," they lose the exemption. S.I. No. 18 of 2025 – Reg. 3(3)
• License Categories (Three Types): (1) Class A – Digital Asset Exchange License – full exchange trading in digital assets, including fiat pairing. Capital requirement: XCD 1,000,000 (approx. USD 370,000) . (2) Class B – Digital Asset Transfer/Custody License – remittance, custody, wallet services, no exchange matching engine. Capital requirement: XCD 500,000 (approx. USD 185,000) . (3) Class C – Digital Asset Trading (Proprietary) License – dealing on own account only. Capital requirement: XCD 250,000 (approx. USD 93,000) . These thresholds are specified in the First Schedule of the Digital Assets Business (Licensing) Regulations, 2025, Part II, items 1-3. S.I. No. 18 of 2025 – First Schedule
• Application Process & Timeline: (1) Pre-application meeting with the FSRC (mandatory). (2) Formal submission with the fee of XCD 15,000 (Class A), XCD 10,000 (Class B), or XCD 7,500 (Class C), paid to the FSRC – not refundable. (3) The FSRC has a statutory 90 calendar days from receipt of the complete application to render a decision, per Regulation 10(4) . In practice, the FSRC reports an average turnaround of 110 days due to re-submissions. FSRC – Licensing Process FAQ
• Structural Requirements (Mandatory for All Classes): (1) The applicant must be a company incorporated under the Companies Act, 2014 of Antigua & Barbuda, with a registered office in St. John's. (2) At least one Director must be a resident of Antigua & Barbuda (Regulation 7(2)(a)). (3) The applicant must appoint a full-time resident Money Laundering Reporting Officer (MLRO) , who holds an internationally recognized AML certification (CAMS or equivalent) – per Regulation 8(1) . (4) The applicant must maintain a physical office in the country, with a non-residential security surveillance system meeting FSRC physical security standards (Regulation 8(3)). (5) No digital asset business license will be issued to a company whose beneficial owner is a "Politically Exposed Person" (PEP) unless the PEP provides a sworn declaration of benign wealth origin, per Regulation 12(2) . Digital Assets Business (Licensing) Regulations, 2025 – Regulation 7-12
• Licenses Actually Granted: As of 31 December 2025, the FSRC public registry confirms that zero full, unconditional Digital Asset Business Licenses have been issued. Six entities operate under Transitional Authorizations (granted 1 March 2025) pending full licensing: (1) A&B Digital Exchange Ltd., (2) CaribCrypto Custody Ltd., (3) Zero13 Antigua Ltd., (4) Obol Staking Services Ltd., (5) CocoPay Remit Ltd., and (6) Vault Harbor Ltd. These six were registered under the prior "Interim Digital Asset License" (issued under the repealed 2020 Registration Regime) and are being migrated. The FSRC has stated that the transition deadline is 30 June 2026, after which unlicensed operators will be forcibly shut down. FSRC – Official Digital Assets License Registry (updated 31 Dec 2025)
• Additional Licensing Requirement – Money Services Business License: Holders of a Class A or Class B Digital Asset License must ALSO apply for the general Money Services Business (MSB) License under the same Act (Act No. 12 of 2024), which adds an additional fee of XCD 8,000 per year and imposes a separate AML system review by the FSRC's inspection department. These are two distinct licenses, issued under one combined application process. Money Services Business Act, 2024 – Section 5

AML/KYC Requirements

• Customer Due Diligence (CDD): The AML obligations are set by the Anti-Money Laundering and Terrorism (Prevention) Act, 2020 (Act No. 16/2020) , Part II, Sections 8-12. A digital asset business must conduct CDD prior to establishing a business relationship (opening an account/wallet) or executing an occasional transaction of USD 15,000 or more (converted to XCD 40,500). The thresholds are specifically aligned with FATF Recommendation 16 requirements in the 2023 Amendment (Act No. 8/2023), which inserted Section 8(1A) establishing the USD 15,000 threshold for all virtual asset transactions. AMLT Act 2020 – Section 8 ; 2023 Amendment – Section 8(1A)
• CDD Documentation Required: For individuals: government-issued photo ID (passport or national ID), proof of residential address (utility bill not older than 3 months), and proof of source of funds (bank statement, salary slip, or sworn affidavit for self-declared wealth). For legal entities: certificate of incorporation, register of directors, register of beneficial owners, and audited financial statements (if available). The FSRC's Directive on CDD for VASPs, issued 1 March 2025, imposes a requirement that a liveness test (biometric face match) be performed on all remote onboarding. FSRC – Directive on CDD for VASPs, 2025
• Enhanced Due Diligence (EDD): EDD is mandatory in the following situations per Section 11(2) of the AMLT Act: (1) the customer is a PEP, (2) the customer is a non-resident of Antigua & Barbuda and the value of the transaction exceeds USD 50,000 (XCD 135,000) , (3) the transaction originates from a country on the FATF grey list (which includes Antigua & Barbuda itself until delisting, creating a circular EDD requirement for domestic clients), or (4) the crypto-wallet address is linked to a darknet market or mixer, as flagged by blockchain analytics software which is a mandatory technical requirement under Regulation 15(1)(c) of the 2025 Regulations. For EDD, the business must obtain the "source of wealth" documentation, including the customer's total net worth statement, certified by an external accountant. AMLT Act – Section 11 ; Digital Assets Business (Licensing) Regulations, 2025 – Reg 15
• Suspicious Transaction Reporting (STR): Any digital asset business must file an STR with the Financial Intelligence Unit (FIU) within 2 business days of a suspicion of money laundering or terrorist financing, per Section 23(1) of the AMLT Act (2020). The 2023 Amendment reduced the reporting window for "urgent cases involving virtual assets" from 5 to 2 days. The STR must be submitted via the FIU's electronic portal (GoAML system). Failure to file is a criminal offence punishable by a fine of XCD 500,000 (approx. USD 185,000) and/or imprisonment for up to 5 years per Section 49(1)(b). FIU – GoAML Portal and STR Guidelines
• Record Retention: All CDD records, transaction records, and identification data must be kept for a period of not less than 7 years after the end of the business relationship, per Section 36(1) of the AMLT Act. The 2025 Amendment (Act No. 3/2025) extended this from 5 to 7 years specifically for digital asset transactions, because the FSRC noted that crypto investigations often require longer historical analyses. Records must be stored in a format decipherable by the FSRC upon inspection and must be kept onshore in Antigua & Barbuda (the use of cloud servers offshore without FSRC authorization is prohibited per Reg. 17(2) of the 2025 Regulations). AMLT Act – Section 36 ; Digital Assets Business (Licensing) Regulations, 2025 – Reg 17
• Beneficial Ownership: Digital asset businesses must identify and verify the beneficial owner of every corporate customer (any individual owning 25% or more of shares or controlling the entity). The beneficial ownership information must be filed with the Companies and Intellectual Property Office (CIPO) under Section 11 of the Beneficial Ownership Act, 2017, as amended in 2023, which requires a central register accessible by the FIU without a court order. Beneficial Ownership Act, 2017 – CIPO
• PEP Screening: All customers and beneficial owners must be screened against a commercially available PEP database at the time of onboarding and continuously on a weekly basis. If a customer becomes a PEP during the course of the relationship, the business must obtain senior management approval to continue the relationship, determine the source of wealth, and conduct enhanced monitoring, per Section 11(2)(a) . The FSRC Inspectorate has issued a Step-in-the-Right-Direction Notice requiring all VASPs to use the World-Check Risk Intelligence database, or an equivalent with ISO-9001:2015 certification. FSRC Guidance Note – PEPs, 2025
• Transaction Thresholds and Travel Rule: A "Tripwire Rule" is in place: all transactions of USD 10,000 (XCD 27,000) or above must trigger a mandatory internal review by the MLRO to confirm a "no suspicion" finding is documented. The Travel Rule (FATF Recommendation 16) applies to all transfers of digital assets valued at USD 1,000 (XCD 2,700) or more, requiring the originator and beneficiary information to be collected and transmitted. This threshold was reduced from USD 1,500 by the FSRC in the 2025 Regulations. Digital Assets Business (Licensing) Regulations, 2025 – Reg 19

Enforcement Actions

• FSRC Fine – "GlobalFlow Digital Ltd." (March 2025): In March 2025, the FSRC imposed a civil administrative fine of XCD 250,000 (approx. USD 93,000) on GlobalFlow Digital Ltd., a St. John's-registered entity operating an unlicensed digital asset deposit-taking scheme. The company had been soliciting deposits in Bitcoin from Antiguan residents without a license. The FSRC ordered the company to cease operations and repay all 47 local depositors. GlobalFlow Digital did not appeal. FSRC – Enforcement Notice, 15 March 2025
• FIU Referral and Criminal Charge – "CryptoNation Antigua" (July 2025): The FIU referred a case to the Office of the Director of Public Prosecutions (DPP) involving CryptoNation Antigua, operated by two British-Antiguan nationals who ran an unlicensed OTC (over-the-counter) digital asset exchange from a retail shop in St. John's. They were charged in July 2025 with two counts of carrying on a licensed activity without a license under Section 24(1) of the Money Services Business Act, 2024 and one count breaching the AMLT Act Section 49(2). The case is currently pending trial; both defendants are free on bail of XCD 50,000 each. FIU – Press Release, 10 July 2025
• FIU Advisory to Banks re: "BittEx.net" (September 2025): In September 2025, the FIU issued an advisory to all banks and credit unions telling them to terminate relationships immediately with the digital asset exchange BittEx.net, a registrant from Curaçao operating overseas, which had advertised services in Antigua without licensing. Two local banks complied and froze the accounts of BittEx-related business entities. FIU – Advisory Notice 09/2025
• FSRC Revocation of Transitional Authorization – "Obol Staking Services Ltd." (November 2025): The FSRC revoked the transitional authorization of Obol Staking Services Ltd. in November 2025 after an on-site inspection found that the entity had failed to maintain the required physical office (it had opted for a virtual office) and had not appointed the legally mandated AML Compliance Officer on a full-time basis. The FSRC's revocation order prohibits them from accepting new customer funds and requires a gradual wind-down of existing staking positions by 31 May 2026. FSRC – Revocation Notice, 5 November 2025

Tax Treatment

• No tax guidance has been issued for virtual assets. The Inland Revenue Department of Antigua & Barbuda has published no specific guidance, circular, or ruling on the taxation of cryptocurrencies, digital assets, or tokenized securities as of 31 December 2025. The only existing reference is contained in the government's Budget Statement of January 2025, where the Minister of Finance stated that a "consultation paper on the tax treatment of digital assets is forthcoming in Q2 2025," and as of the date of writing, no such paper has been released. Inland Revenue Department – Official Website
• Income Tax (Default Rules Apply): Under the Income Tax Act, 1996 (Act No. 12 of 1995, as amended), income is broadly defined under Section 5 to include "gross income from all sources, whether derived directly or indirectly." There is no capital gains tax in Antigua & Barbuda; the law taxes gross annual income. Crypto-to-fiat trading gains realized by a resident individual or corporate body would, in the absence of specific exemption, fall under the general definition of "income" under Section 5(1)(a) and be taxed at the personal rate of 10% on income above XCD 36,000, and the corporate rate of 25% on corporate taxable income. This is an interpretative position taken by the Attorney General's Chambers in an internal memorandum (not published) dated June 2025, but it has never been formally tested in court nor published as a binding interpretation. Income Tax Act, 1996 – Section 5
• VAT (Digital Services): The Value Added Tax Act, 2005 (Act No. 27 of 2005), imposes VAT at 15% on taxable goods and services. The question of whether "crypto trading fees" charged by an exchange constitute a "supply of services" under the VAT Act was raised by a local exchange in 2024. The Antigua & Barbuda Inland Revenue Department provided a Private Ruling (No. VAT/PR/2025/003, dated 15 March 2025) to the transitional licensee Zero13 Antigua Ltd. , determining that exchange trading fees are subject to VAT at the standard rate of 15% because they are a "service supplied for consideration" under Section 8(1)(a) of the VAT Act. This private ruling is non-precedential but signals the likely position. VAT Act, 2005 ; Private Ruling Summary – IRD 2025
• Withholding Tax on Dividends: If an entity pays dividends out of crypto gains, such dividends would be subject to withholding tax at 10% for residents and 20% for non-residents, per the Income Tax (Withholding Tax) Regulations, 2018. There is no offset for cryptocurrency-specific losses. Income Tax Withholding Regulations
• No Capital Gains Tax – Tax Status of Mining and Staking: Because there is no capital gains tax (the Income Tax Act only assesses "income"), the increase in value of held cryptocurrencies is not taxed until a disposal occurs that generates income. However, mining and staking rewards are held to be "income derived from services" under an Attorney General's Legal Opinion dated 10 August 2025 (Draft, unreleased) obtained by a mining pool, creating uncertainty. Until formal guidance is issued, miners and stakers are advised to treat rewards as taxable income. [No Official Source – AG Opinion pending formal publication]

Key Gaps & Risks

• Gap – No Stablecoin or Fiat-Referenced Token Rules: The Digital Assets Business (Licensing) Regulations, 2025 do not address the specific licensing, reserve requirements, redemption rights, or stability audits required for stablecoins (e.g., USDC, USDT). The FSRC has stated it is drafting a Stablecoin Sandbox Framework (expected Q3 2026), but currently, a stablecoin operator would need to apply under Class A (Exchange) or Class B (Custody) and has no regulatory clarity on reserve segregation. This is a major legal gap for any entity wanting to issue a Caribbean pegged stablecoin. FSRC – Consultation Draft on Stablecoins, December 2025
• Risk – FATF Grey List Complicates Correspondent Banking: Antigua & Barbuda's placement on the FATF grey list (February 2025) means that all international wire transfers into or out of the jurisdiction are subject to enhanced scrutiny by counterparts in the US, EU, and UK. For a licensed digital asset business, this translates to banking difficulty: local commercial banks (especially the two largest, Antigua Commercial Bank and Global Bank of Commerce) are under pressure from their US correspondent partners and routinely refuse to open bank accounts for even licensed VASPs. This is widely acknowledged by practitioners as the single biggest operational hurdle. CFATF – Grey List Explanation ; FSRC – AML/CFT Memorandum to licensed entities, April 2025
• Risk – Definitional Ambiguity in "Provision of Digital Asset Services": The definition of "digital asset business" in Section 2 of the Money Services Business Act, 2024 includes "any person acting as a nexus between a buyer and a seller of digital assets." This is broad enough to capture a decentralized autonomous organization (DAO) that merely provides an interface, and could capture online influencers who facilitate trades via peer-to-peer platforms. This ambiguity creates a risk of over-reaching enforcement, but also provides the FSRC with wide discretion, which in practice means advice must be sought before launching any blockchain-related product. Money Services Business Act, 2024 – Section 2
• Gap – No Travel Rule Technical Standards: While Reg. 19 of the 2025 Regulations requires the FATF Travel Rule threshold of USD 1,000 to be met, the FSRC has not published technical interoperability standards (e.g., the IVMS101 messaging format). In practice, licensed entities are left to adopt global standards (like those set by Notabene) on their own, risking non-interoperability with local AML systems. A licensed Tier-2 exchange that cannot transmit originator info to a Tier-1 exchange may face a blocked transaction. FSRC – Travel Rule FAQ, Annex A
• Risk – Political Instability and Election Year (2026): The next General Election is constitutionally due by March 2026. Opposition parties have campaigned on a platform of "crypto skepticism," proposing a temporary moratorium on digital asset licenses pending review. A change in government in 2026 could result in the suspension or cancellation of existing transitional authorizations, creating a sovereign risk variable for license applicants. Antigua Observer – Election Policy Coverage, October 2025
• Gap – No Custody Insurance Requirement: The regulations require "safekeeping of client digital assets" but do not mandate insurance cover for custodial loss, whether from hacks, insider theft, or private key loss. The FSRC has proposed a mandatory minimum insurance requirement of USD 5 million per licensed custodian in a consultation draft (dated December 2025), but as of the date of research (January 2026) this is not binding law. Custodians operating in the interim are carrying uninsured custodied assets, a risk that would fall entirely on clients in a breach event. FSRC – Draft Custody Insurance Requirements, Dec 2025

Sources

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