Walkers' regulatory partners Lucy Frew and Ian Mason consider the learning points for financial services providers (FSPs) from recent enforcement actions by Cayman regulatory bodies. .
VASP Transitional Provisions
The Virtual Asset Service Providers (Amendment) Act, 2020
( VASP Amendment Act ) is now in force, as of 15 January
2021. The VASP Amendment Act supports the continuing
implementation of Cayman Islands virtual asset service
provider regulatory framework by allowing persons engaged in the
provision of virtual asset services ( VASPs ) to continue
operating as the provisions of the Virtual Asset (Service
Providers) Act, 2020 (the Act ) are commenced.
Notably, the VASP Amendment Act brings the Virtual Asset (Service
Providers) (Savings and Transitional) Regulations, 2021
( Savings and Transitional Regulations ) into
effect.
The Savings and Transitional Regulations provide that:
(a) a VASP who:
(ii) is not an