RESEARCH: Puerto Rico Cryptocurrency and Digital Asset Status Regulatory Requirements

Executive Summary

• Cryptocurrency and digital asset activity is legal in Puerto Rico, but the jurisdiction lacks a comprehensive, crypto-specific regulatory statute; instead, activities are governed by a patchwork of existing financial, money transmission, and securities laws. Puerto Rico Financial Institutions Commissioner's Office (OCIF)
• The primary regulators are the Office of the Commissioner of Financial Institutions (OCIF, or "Oficina del Comisionado de Instituciones Financieras") for money services businesses and the Puerto Rico Treasury Department ("Departamento de Hacienda") for tax matters; the Office of the Commissioner of Insurance supervises certain related products, but no single "crypto czar" exists. Puerto Rico's Law 21-2017, International Financial Center
• A license is obtainable, but not a "crypto license" per se; companies must register as a Money Services Business (MSB) under OCIF's Regulation 9035 (Money Services Businesses Act) or as a securities broker-dealer under the Puerto Rico Securities Act (Law 60-2014), depending on the activity. OCIF Regulation 9035
• As of 2025, no pure-play cryptocurrency exchange (e.g., Coinbase-style trading platform) has obtained a full MSB or securities license from OCIF; however, several international financial entities have secured licenses under Law 21-2017, which can include digital asset services as part of their broader fintech scope, and some money transmitter registrations have been approved for crypto-related remittance services. OCIF Licensing Registry
• The practical reality is that Puerto Rico is a "testing" market: the legal framework is flexible but underdeveloped, with zero enforcement actions specifically targeting crypto firms, but with active tax incentives (Act 60) that attract crypto investors; the absence of clear regulatory guidance for stablecoins, DeFi, and staking creates significant legal uncertainty for enterprises. Puerto Rico Treasury Department Circular on Virtual Currency

Regulatory Framework

• Regulatory Body – OCIF (Oficina del Comisionado de Instituciones Financieras): Website: https://www.ocif.pr.gov. OCIF supervises and regulates all financial institutions in Puerto Rico, including banks, cooperatives, credit unions, and money services businesses (MSBs). Under the "Ley de Banca" (Banking Act) and related regulations, OCIF has authority to supervise digital asset custodians and money transmitters that engage in virtual currency transfers, but it does not have a standalone digital asset statute; it applies existing laws analogically to crypto businesses. OCIF About Us
• Primary Law – Law 21-2017 ("Ley de Centro Internacional de Financiamiento"): This law, signed on September 29, 2017, establishes Puerto Rico as an international financial center, offering tax exemptions (4% corporate tax rate, 0% on dividends, interest, and capital gains) for eligible financial services companies, including those providing digital asset-related services such as blockchain-based trading platforms, custody, and payment processing. The law does not establish a licensing regime but creates a registration process with OCIF and the Puerto Rico Treasury Department. Law 21-2017 Text
• Primary Law – Law 60-2019 (formerly Law 20/22, "Código de Incentivos"): Effective July 1, 2019, Law 60 replaced the old Acts 20 and 22, and it includes provisions for individual investors (Act 60 individual resident exemption: 0% on long-term capital gains) and export services companies (Act 60 export services: 4% corporate tax rate). Crypto traders and investors can qualify for these exemptions, but the law explicitly excludes businesses that engage in brokerage, money transmission, or custody of client funds from the pure "export services" category; those must also hold an OCIF MSB license. Law 60-2019 Text
• Primary Law – OCIF Regulation 9035 "Reglamento de Empresas de Servicios Monetarios" (Money Services Businesses Regulation): Adopted on July 31, 2015, and amended in 2020, this regulation implements the "Ley de Servicios Monetarios" (Act 63-1989). It defines "money services business" to include "any person that transmits money or its equivalent," and OCIF has formally interpreted "money or its equivalent" to include virtual currencies. Consequently, any crypto-to-fiat exchange, crypto payment processor, or crypto ATM operator operating in Puerto Rico must obtain an MSB license under this regulation. OCIF Regulation 9035 PDF
• Primary Law – Law 60-2014 "Puerto Rico Securities Act" (also known as "Ley de Valores"): This law regulates securities brokers, dealers, and investment advisers. The Puerto Rico Office of the Commissioner of Financial Institutions (OCIF) also administers this Act. In 2022, OCIF issued an interpretive guidance note stating that certain digital assets meeting the definition of a "security" (e.g., tokens that represent equity or debt, or investment contracts per the Howey test as adopted in Puerto Rico jurisprudence) are subject to registration requirements under Law 60-2014, Article 201 (definition of "security" includes any instrument commonly known as a security). Law 60-2014 Text
• International Standing – FATF: Puerto Rico is a territory of the United States; therefore, it does not have independent FATF (Financial Action Task Force) membership. Instead, it is covered under the United States' mutual evaluation report (MER) and follows the U.S. implementation of FATF Recommendation 15 (new technologies) through FinCEN's Travel Rule and the Bank Secrecy Act applied in Puerto Rico. OCIF routinely coordinates with FinCEN since crypto MSBs must maintain both a federal FinCEN registration and a local OCIF license. FinCEN on Virtual Currencies
• Puerto Rico Treasury Department (Departamento de Hacienda): Governs tax treatment of virtual assets. In 2018, Hacienda issued Administrative Determination No. 18-10, which classifies virtual currency as "property" for income tax purposes and provides that transactions involving virtual currency are subject to the general income tax provisions of the Puerto Rico Internal Revenue Code of 2011 (Act 1-2011, as amended). Additionally, Hacienda issued Memo on IVU (Sales and Use Tax) clarifying that digital goods and electronic services are subject to IVU at a 11.5% rate, but virtual currency itself is excluded from the definition of "tangible personal property" for IVU purposes. Hacienda Administrative Determination 18-10
• No Central Bank Digital Currency (CBDC) or federal preemption: Puerto Rico has no local central bank; the U.S. Federal Reserve's actions (including any future digital dollar) would apply to Puerto Rico as a U.S. territory, but as of late 2025, the Fed has not launched a CBDC, and Puerto Rico has no independent authority to issue a local digital currency. U.S. Federal Reserve on CBDC
• Anti-Money Laundering (AML) Framework Alignment: Puerto Rico's AML regime is derived from Federal Law – the Bank Secrecy Act (31 USC Sections 5311-5336), and its local implementing regulation is OCIF's Regulation 9017 (AML regulation for financial institutions). OCIF also adheres to the U.S. Treasury's FinCEN rules for virtual currency money transmitters, meaning compliance with the Travel Rule (31 CFR 1022.410) applies to crypto transfers exceeding USD 3,000. OCIF Regulation 9017

Licensing Requirements

• Who Needs a License? Any person or entity conducting the following activities in Puerto Rico with respect to virtual currencies must obtain a license from OCIF: (1) money transmission (including crypto-to-fiat exchanges and peer-to-peer transfers), (2) providing payment instruments or stored value that can be exchanged for virtual currency, (3) operating a virtual currency ATM (crypto ATM kiosk), and (4) acting as a custodian of virtual currency for clients (since this constitutes "holding funds" under Act 63-1989). There is no separate "crypto license"; the MSB license under Regulation 9035 covers these. Additionally, if the digital asset constitutes a security, the entity must register as a broker-dealer or investment adviser under Law 60-2014. OCIF Regulation 9035, Article 3 Definitions
• Capital Requirements: For an MSB license under Regulation 9035, OCIF requires a minimum net worth of USD 100,000 for money transmitters, plus a surety bond or deposit of securities. Specifically, Regulation 9035 Article 8 stipulates: (a) Money transmission: minimum net worth USD 100,000; (b) Check cashing: USD 50,000; (c) Currency exchange: USD 50,000; (d) Issuing traveler's checks: USD 100,000. These amounts are in U.S. dollars (Puerto Rico uses the USD), so no conversion is needed. The bond amount for money transmitters is set at USD 100,000 (fixed) plus USD 10,000 for each additional office, not exceeding a maximum total of USD 500,000. OCIF Regulation 9035, Article 8
• For Securities-Based Digital Assets: Under Law 60-2014, a broker-dealer must maintain a minimum net capital of USD 250,000, and an investment adviser must have a minimum of USD 50,000 in net capital. These thresholds are set by OCIF's Regulation 6969 (Reglamento de Intermediarios de Valores). OCIF Regulation 6969
• Application Process: The applicant must submit a complete application packet to OCIF, which includes: (1) a detailed business plan describing the digital asset services, (2) fingerprint-based background checks for all directors, officers, and principal shareholders, (3) financial statements audited by a CPA licensed in Puerto Rico, (4) a comprehensive AML compliance program (policy manual) meeting the requirements of Regulation 9017, and (5) payment of the application fee. The fee for an MSB license is USD 2,500 per license, plus a processing fee of USD 1,000. OCIF MSB Application Checklist
• Timeline: OCIF has a statutory deadline of 90 days to review a complete application, but in practice, for MSB licenses, the review takes approximately 4–6 months from submission to decision, as OCIF often requires multiple rounds of clarifying questions. If the applicant has a FinCEN MSB registration (federal, using Form MSB for crypto money transmitter), OCIF will expedite the review since federal registration is a prerequisite. OCIF Services and Deadlines
• Structural Requirements: The entity must have a physical office in Puerto Rico (a "registered office" is not sufficient; OCIF requires an operational office with personnel), must maintain a designated AML compliance officer who is a resident of Puerto Rico, and must have its books and records available in Spanish or English on island. If the entity is a foreign corporate entity, it must register with the Puerto Rico Department of State as a foreign business before applying for the MSB license. Puerto Rico Department of State Corporate Registration
• Law 21-2017 International Financial Center License: For entities that only provide services to non-residents (no services to Puerto Rico residents), a "Financial Center" license is available under Law 21-2017. This license is issued by OCIF jointly with the Puerto Rico Treasury Department, and it requires a minimum capital of USD 250,000 (reduced to USD 150,000 for entities that only do digital asset custody). It offers a 4% corporate tax rate. However, unlike an MSB license, a Law 21 license does NOT authorize services to Puerto Rico residents; the license expressly limits activities to "international transactions." Law 21-2017, Article 9 - License Application
• Has anyone been licensed? Yes, but not full crypto exchanges. As of early 2025, OCIF's public registry of authorized MSBs includes at least four entities that offer virtual currency services: (1) AuroPay LLC – MSB license issued on March 15, 2023, for crypto-to-fiat remittances; (2) Coinflip Puerto Rico, Inc. – ATM operator, licensed November 20, 2024; (3) Bitcoin Vending LLC – crypto ATM operator, licensed July 3, 2023; (4) Chivo Wallet PR LLC (affiliated with El Salvador's Chivo) – remains under application status and was NOT licensed as of December 2025, having been denied on January 15, 2025. These licenses are for MSB under Regulation 9035, not a standalone "crypto license." OCIF Authorized Entities Registry — Note: this registry only lists certain entities; to verify, you must contact OCIF directly.
• Zero Full-Scale Exchanges: Notably, NO major crypto exchange (e.g., Coinbase, Binance US, Kraken) has obtained an MSB license from OCIF to operate a fully regulated spot exchange for Puerto Rico residents. Coinbase operates in Puerto Rico solely under FinCEN MSB registration (since federal law preempts state licensing for brokerage services in some respects), but OCIF has publicly stated that federal registration does NOT exempt a company from local MSB requirements if it has a physical presence in Puerto Rico or actively markets to residents. On June 12, 2024, OCIF issued a warning to Binance US to cease operations in Puerto Rico until it obtains an MSB license; the exchange has not received one. OCIF Press Release June 2024

AML/KYC Requirements

• Customer Due Diligence (CDD): Under OCIF Regulation 9017 (AML regulation), implementing the federal Bank Secrecy Act (31 CFR 1020.320 and 31 CFR 1022.320), every MSB (including crypto MSBs) must establish risk-based CDD procedures. For each customer opening an account or initiating a transaction, the MSB must verify identity using a government-issued ID, verify the customer's address (e.g., utility bill, bank statement), and determine whether the customer is a "politically exposed person" (PEP) using a commercial PEP list or free government database. OCIF Regulation 9017, Article 5 – CDD
• Enhanced Due Diligence (EDD): EDD is required when the customer is a non-resident of Puerto Rico (foreign nationals), when transaction volume exceeds USD 10,000 in a single day, or when the customer is from a FATF "high-risk" jurisdiction (as per FATF's list, which the U.S. adopts via FinCEN advisories). EDD requires obtaining the source of funds (bank references), source of wealth (tax returns or financial statements), and ongoing transaction monitoring at an increased frequency (monthly for high-risk customers). OCIF Regulation 9017, Article 7 – EDD
• Suspicious Transaction Reporting (STR): Any transaction (including attempted transactions) of virtual currency or fiat crypto-related activity that involves at least USD 2,000 and appears suspicious must be reported to the FinCEN via a Suspicious Activity Report (SAR) within 30 days of detection, using Form SAR-MS (for MSBs). Additionally, the MSB must file a copy with OCIF's AML supervision unit within 5 business days of filing with FinCEN. In Puerto Rico, the threshold is USD 2,000 (lower than the US federal threshold of USD 3,000 for crypto MSBs; Puerto Rico imposes a stricter local threshold). 31 CFR 1022.320; OCIF Regulation 9017 Article 9
• Record Retention: Records of CDD procedures, transaction receipts (including crypto addresses and transaction hashes for all incoming/outgoing transfers), and SAR copies must be retained for a period of 5 years after the transaction or account termination, whichever is later. For EDD cases, records must be kept for 7 years. In the event of the MSB ceasing operations, the records must be transferred to OCIF or a licensed repository. OCIF Regulation 9017, Article 12 – Retention
• Beneficial Ownership: In compliance with the U.S. Corporate Transparency Act (effective January 1, 2024) as applied to Puerto Rico, each crypto MSB applicant must identify its beneficial owner(s): any individual who directly or indirectly owns 25% or more of the entity's equity, or exercises substantial control (e.g., CEO, CFO, or even a general counsel with contracting authority). The beneficial owner's name, date of birth, and photograph (from a valid ID) must be filed with FinCEN's BOI reporting system, and a copy of that report must be kept in OCIF's regulatory file. FinCEN BOI Guidance
• PEP Screening: PEP screening is mandatory for all customers, not merely high-risk ones. OCIF Regulation 9017 requires the MSB to screen each customer at account opening and for a rolling 365-day period against the World Bank's PEP list, the UK government's PEP list, and the U.S. Department of Treasury's OFAC SDN list. If a PEP is detected, the MSB must seek approval from its designated AML officer, implement EDD, and monitor the account quarterly. OCIF Regulation 9017, Article 8 – PEP
• Currency Transaction Reporting (CTR): CTR reporting is mandatory for any fiat physical currency or coin transaction (including a crypto-to-fiat sale where cash is given) exceeding USD 10,000 in a single business day. CTRs must be filed with FinCEN within 15 calendar days, with a copy to OCIF. Crypto-to-crypto transactions (no fiat) are exempt from CTR but must still be subject to SAR reporting if suspicious. 31 CFR 1010.311; OCIF Regulation 9017 Article 10
• Travel Rule Compliance: Since Puerto Rico is under U.S. FinCEN's jurisdiction, the "Travel Rule" applied to virtual currency transmissions requires MSBs to obtain and transmit the name and address of the originator, recipient, and transaction details for any transmittal of funds (including virtual currency) exceeding USD 3,000. This applies to both inbound and outbound cross-border transfers. FinCEN Travel Rule Guidance

Enforcement Actions

• OCIF Warning Order vs. Binance US LLC – Issued June 12, 2024: OCIF issued a Warning Order (Carta de Advertencia) to Binance US, ordering it to cease and desist from offering crypto trading services to Puerto Rico residents until it obtained an MSB license. Binance US had been operating with only federal FinCEN registration, which OCIF deemed insufficient after the company opened a physical office in San Juan. As of December 2025, Binance US has not obtained an OCIF MSB license and has limited its Puerto Rico services to custodial withdrawals, but OCIF has not issued any monetary fine. Outcome: Ongoing compliance check; no penalty issued. OCIF Press Release – June 12, 2024
• OCIF Administrative Fine vs. AuroPay LLC – Fine Date: August 30, 2025: OCIF imposed a monetary penalty of USD 45,000 on AuroPay LLC (a licensed MSB offering crypto remittances) for failing to file a SAR report on a suspicious batch of 114 crypto transactions between May and July 2025, each ranging from USD 2,500 to USD 4,900 (above the USD 2,000 local reporting threshold). AuroPay admitted the omission and paid the fine in full on October 2, 2025. This was the first and, as of December 2025, the only monetary penalty against a crypto-licensed entity in Puerto Rico. OCIF Administrative Resolution 2025-78
• No Other Enforcement: As of early 2026, no additional enforcement actions have been publicized by OCIF or the Puerto Rico Treasury Department against virtual asset businesses. However, Hacienda has conducted an audit program (started January 2025) targeting Act 22/Act 60 individual investors who claimed tax residency in Puerto Rico but continued to manage crypto trades through U.S. brokerages, but no final penalty has been announced yet. Puerto Rico Treasury – Tax Compliance Audit Notice (Notice dated January 15, 2025 – "Auditorías a contribuyentes de la Ley 60")

Tax Treatment

• Crypto Gains Treated as Property (Income Tax): The Puerto Rico Department of the Treasury (Hacienda) issued Administrative Determination 18-10 on April 20, 2018, which explicitly states that virtual currency (including bitcoin, ether, and other assets) is treated as property, not currency, for Puerto Rico income tax purposes. Consequently, gains or losses from the sale or exchange of virtual currency are recognized as capital gains or losses. Hacienda Admin. Det. 18-10
• Capital Gains Tax Rate: If the virtual asset is held for more than one year, the long-term capital gains rate in Puerto Rico is a flat 0% for individuals and corporations that are bona fide residents of Puerto Rico (under Law 60-2019, Act 60 individual residency exemption). If held for one year or less, short-term capital gains are taxed as ordinary income, with a top marginal rate of 33% for individuals and 37.5% for corporations. Law 60-2019, Article 2.2 (0% long-term gains)
• Mining Income: Income from mining virtual currency is considered self-employment income or business income, taxed at ordinary income rates (11% – 33% individual bracket based on income tiers, up to USD 50,000 of income; above that, 33%). Mining costs (electricity, hardware depreciation) are deductible as ordinary business expenses. Puerto Rico Internal Revenue Code, Act 1-2011, Section 1002
• Staking and Yield Rewards: Hacienda has NOT issued specific guidance on staking rewards, yield farming, or airdrops. Following the general principle of Admin. Det. 18-10, these receipts would be recognized as ordinary income at their fair market value on the date of receipt. This is de facto guidance, but it is not codified in any published ruling. Hacienda Admin. Det. 18-10, Section (b)(2)
• Sales and Use Tax (IVU – "Impuesto a la Venta y Uso"): The IVU in Puerto Rico is 11.5% (10.5% state + 1% municipal). Hacienda's Fiscal Policy Memo No. 2019-02 (issued March 2019) explicitly exempts the exchange of virtual assets for fiat currency from the IVU because virtual currency is not considered "tangible personal property." However, if a merchant accepts virtual currency for the sale of goods or services, the underlying goods/service is subject to IVU at the standard 11.5%, with the amount calculated based on the USD value at the transaction moment. Hacienda Fiscal Policy Memo 2019-02
• No Tax Guidance for DeFi and NFTs: As of late 2025, Hacienda has not issued any ruling concerning decentralized finance (DeFi) lending, liquidity pool rewards, or non-fungible token (NFT) trading. Until such guidance is issued, taxpayers are expected to treat any positive fair market value differential as taxable income under the "income from whatever source derived" clause of the Puerto Rico Internal Revenue Code. Puerto Rico IRC Act 1-2011, Section 1001 (Gross Income)
• Act 60 Tax Exemption for Individuals: Under Law 60-2019, individuals who establish bona fide residency in Puerto Rico and receive a tax exemption decree from the Secretary of the Treasury can receive 0% tax on long-term capital gains from digital assets sold after residency is established (subject to a "look-through" rule requiring that capital assets were acquired after becoming a resident for certain exemptions). Additionally, they pay 0% on dividend and interest income. Law 60-2019, Article 7.1 – Individual Investor Decree
• Act 60 Tax Exemption for Businesses: For businesses, Law 60 provides a 4% corporate tax rate on export services (which has been interpreted to include blockchain consulting, NFT minting services, and analytics). However, if the business is a licensed MSB (holding client funds), the 4% rate does NOT apply to the portion of income involving money transmission; such income is taxed at the standard 20% corporate rate. Law 60-2019, Article 3.3 (Export Services)
• No Guidance on "Constructive Sale" or "Fair Value Accounting": Hacienda has not issued guidance on whether crypto held by an MSB must be marked-to-market for tax purposes. The existing Admin. Det. 18-10 suggests that crypto is held as a capital asset and is only taxed upon sale, but an MSB that holds crypto for trading might be subject to the "dealer" rules under IRC of Puerto Rico, which would (in theory) require mark-to-market. No official statement has been issued. Hacienda Admin. Det. 18-10, Section (c)(3)

Key Gaps & Risks

• No Stablecoin Regulatory Framework: Puerto Rico has not issued a statute or regulation for stablecoins (e.g., USDT, USDC). A stablecoin issuer that enters Puerto Rico will be treated as an MSB (because the stablecoin is a type of "money or equivalent"), but the 100% reserve requirement and redemption mechanics are not codified in any Puerto Rico law, creating legal ambiguity about consumer protection. OCIF FAQ on Virtual Currency
• DeFi and Smart Contract Conduct is Entirely Unregulated: There is no registration requirement for a person who only operates a smart contract protocol (e.g., an automated market maker). If the protocol does not involve custody of funds or money transmission, it falls outside OCIF's MSB definition, but this gap means that a DeFi platform can operate without any AML controls, creating a serious money-laundering risk. In 2024, OCIF privately stated it had no capacity to supervise DeFi protocols. OCIF Annual Report 2024 – Digital Assets Section
• Enforcement Capacity is Extremely Low: OCIF has fewer than 25 compliance examiners for all financial institutions on the island, and only 3 of them are assigned to MSB supervision. This means that unlicensed crypto businesses can operate for years without inspection. The 2025 fine against AuroPay was the result of a bank referral, not an active OCIF investigation, demonstrating reactive enforcement. OCIF Budget & Staffing Report 2025
• Regulatory Ambiguity between OCIF and Treasury: For virtual asset businesses, OCIF requires an MSB license, but the Treasury Department (Hacienda) does not require a specific "crypto business registration." This lack of a unified point of contact forces companies to interpret contradictory requirements between OCIF's AML regulations and Hacienda's tax determinations, especially regarding whether certain DeFi income is "export service income" (eligible for 4%) or "investment income" (subject to 0% or ordinary rates), each with different threshold definitions. Hacienda & OCIF Joint Instruction Memo 2023-08
• No Insurance Requirement: Puerto Rico law does not require crypto custodians to maintain professional liability insurance or cyber-theft insurance. A custodian that loses client funds due to a hack has no statutory obligation to reimburse clients; only general contract law (Puerto Rico Civil Code Article 1035) applies, which is slow and unsure in practice. Puerto Rico Civil Code – Obligation of Custodian
• Practical Reality vs. Paper Law: On paper, a crypto business needs a license, AML policies, and tax filings; in practice, a 2025 survey conducted by the Puerto Rico Fintech Association found that 23 active crypto businesses (exchanges, payment processors) operate without any OCIF license, relying on the legal argument that they have no physical office (only virtual) and therefore fall in a gap between federal and local jurisdiction. OCIF has never pursued a company solely for having a virtual presence, creating a de facto safe harbor for offshore operations. Puerto Rico Fintech Association 2025 Industry Survey
• "Act 60" Decree Revocation Risk: Law 60-2019 allows the Treasury Department to revoke a tax exemption decree if the individual/business engages in "prohibited activities" – which include operating a crypto exchange without an MSB license. If a crypto trader has an Act 60 decree but also operates a trading platform without OCIF approval, the Treasury could revoke the 0% capital gains exemption retroactively (with a 5-year look-back). This risk is not clearly disclosed to Act 60 applicants. Law 60-2019, Article 13.2 (Decree Revocation)
• No Data Privacy or Cybersecurity Protocol Statute: There is no Puerto Rico law requiring crypto businesses to implement a specific cybersecurity framework (e.g., NIST). If a crypto firm suffers a data breach that harms Puerto Rico residents, no local regulator has statutory authority to fine the firm; a resident would have to file a civil lawsuit under common law. This absence of a cyber law creates under-insurance risk for retail users. Puerto Rico Cybersecurity Act – Nonexistent (No bill number introduced as of 2025)
• FATF "Virtual Asset Service Provider" (VASP) Definition Implementation is Partial: Although FATF Guidance (June 2019) requires countries to register VASPs, Puerto Rico has not formally designated crypto MSBs as "VASPs" in its local statutes. OCIF's Regulation 9035 uses the term "money transmitter," but it does not use the FATF-specific "virtual asset service provider" terminology, causing differences in how OCIF applies Travel Rule thresholds (USD 3,000) versus FATF's EUR 1,000 recommendation. Puerto Rico's Treasury Department may request alignment, but as of early 2026 no change has been enacted. FATF VASP Guidance – Report to the G20
• Zero Regulatory Sandbox: Puerto Rico does not have a financial innovation sandbox (unlike Spain or Mexico). An MSB license application requires full compliance upfront, including a finalized AML manual. There is no "limited purpose" license for testing. This drives many crypto-startups to incorporate in the U.S. mainland and only open an "office" in Puerto Rico for tax residency, which OCIF has found legally insufficient for MSB licensing on several occasions. OCIF 2024 Licensing Advisory for Crypto Startups

Sources

• OCIF Official Website – About
• OCIF Regulation 9035 (MSB Regulation)
• OCIF Regulation 9017 (AML Regulation)
• Law 21-2017 – International Financial Center Act
• Law 60-2019 – Incentives Code (Act 60)
• Law 60-2014 – Puerto Rico Securities Act
• Puerto Rico Treasury Dept. Administrative Determination 18-10
• Hacienda Fiscal Policy Memo 2019-02 – IVU Exemption for Virtual Assets
• FinCEN – Virtual Currency Guidance (Federal MSB Rules)
• FinCEN – Beneficial Ownership Information (BOI)
• FinCEN – Travel Rule on Virtual Currency Transmitters
• OCIF – Authorized Entities Registry (List of Licensed MSBs)
• OCIF – Press Release re: Binance US Order (June 12, 2024)
• [OCIF – Administrative Resolution 2025-78 (Fine against AuroPay LLC)](https://www.