---
title: "Curaçao Crypto Regulation Monitor | cryptoassets.gi"
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source_html: /jurisdictions/curacao/index.html
description: "Curaçao crypto asset regulation: 8 categories, 22 sourced findings, updated 2026-10-25. Licensing, token classification, stablecoins, tax treatment."
generated_at: 2026-11-07T14:19:44Z
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---
# Curaçao Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed regulated overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/curacao/)

Last updated 2026-10-25 · 8 categories · 22 sourced
findings · 27 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-10-25 · Position last changed: 2026-10-25 · Record history & provenance &#9662; Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

[Open in Co-Pilot &#8599;](/reports/?type=copilot&j=CURACAO)[Build Report](/reports/?j=CURACAO)[Compare](/compare/?j=CURACAO)

Framework posture Regulated 7 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority CoinDesk Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) 2026-12-31 CGA crypto risk-assessment and wallet-controls deadline

Module coverage & confidence 7 / 9 modules assessed 0 Confirmed · 7 Probable · 0 Uncertain · 2 Not yet assessed

8 Categories

0 Moved this cycle 0 Key judgments 3 Open gaps 22 Findings

0 Tier-1 sources

Confidence mix 8 unpopulated
(sums to 8 rendered categories; click to filter)

No categories moved this cycle.

## Jurisdiction lead brief

###### Latest update · 25 October 2026

#### Lead Signal

Curacao-licensed online-gambling operators face a tightening consumer-protection restriction on how they may handle crypto-assets. The Curacao Gaming Authority prohibits its licensees from performing exchange or virtual-asset-service-provider activity; crypto is permitted only as a payment method for gambling transactions, not as a service the operator itself provides as an exchange function. Full operational compliance with this restriction is required by mid-2027, though the exact date on which the underlying rule itself commenced has not been confirmed from available sourcing.

This is a narrowing of what had been a comparatively permissive overlap between Curacao&#x27;s large offshore gaming sector and crypto-asset activity, and it is best read as a consumer-protection measure aimed at separating gambling-payment functions from exchange-type custody and conversion functions within the same licensed entity.

#### Other Developments

No additional material developments in this module are supported by the sourcing.

#### Cross-Monitor Connections

This restriction is adjacent to the standing virtual-asset-service-provider registration regime administered by the Centrale Bank van Curacao en Sint Maarten, which separately governs licensing of VASPs operating in or from Curacao; the development narrows what gaming licensees specifically may do with crypto rather than changing that broader registration regime. The question of how gaming-sector operators are vetted and monitored also connects to the financial-integrity coverage of a data-security lapse at the gaming regulator&#x27;s own licensing portal, since both concern the adequacy of gaming-sector oversight infrastructure, though the two developments are otherwise unrelated.

#### Outlook

The principal open question is whether CGA or CBCS will publish primary instrument text confirming the commencement date of the exchange-activity prohibition and clarifying enforcement mechanics ahead of the mid-2027 full-compliance deadline. Until such text is available, assessment of this restriction rests on secondary industry reporting rather than confirmed regulatory source material.

2 earlier updates not shown here.

###### Standing brief · as of 28 September 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

Curacao&#x27;s Landsverordening toezicht virtuele activa dienstverleners (VASP Act) is now the settled fact of this jurisdiction&#x27;s crypto-licensing landscape: enacted 13 March 2025 and in force via a Landsbesluit dated 24 June 2025, it requires any virtual asset service provider operating in or from Curacao to hold licensing or registration with the Centrale Bank van Curacao en Sint Maarten (CBCS). Secondary reporting describes the Act as replacing a prior 2024 mandatory-registration-only phase with a fuller licensing regime, a transitional detail that should be read as probable rather than confirmed given its single-source T3 sourcing. Together these developments mark Curacao&#x27;s shift from an unregulated treatment of virtual-asset activity to a CBCS-supervised regime.

#### Other Developments

Sector-specific wallet controls. A distinct but related development sits in the gambling sector rather than in general crypto regulation: the Curacao Gaming Authority&#x27;s crypto policy guideline, effective June 2026, requires strict segregation of player, operational and treasury crypto wallets among CGA licensees, and bans the use of personal or owner-linked wallets. This is a consumer-protection-relevant control specific to gambling operators accepting cryptocurrency, not a general Curacao crypto-custody rule, and it overlaps with the advennt monitor&#x27;s licensing domain.

Stablecoin preference signal. The same CGA guideline expresses a preference for fiat-backed stablecoins over other token types for gambling-sector crypto transactions, requiring additional risk assessment where other token types are used. This is a sector-specific disclosure and risk-management signal rather than a general Curacao stablecoin-issuance framework, and it is not being written up as a standalone module this cycle.

#### Cross-Monitor Connections

The CGA crypto policy guideline&#x27;s wallet-segregation and sanctioned-wallet controls sit at the intersection of this monitor&#x27;s crypto_licensing and consumer_protection findings and the advennt monitor&#x27;s gambling-regulation coverage, and also connect to the financial_integrity monitor&#x27;s AML/CFT domain given the guideline&#x27;s sanctions-screening and blockchain-analytics components. The VASP Act&#x27;s own alignment with FATF Recommendation 15 (the travel rule) is a further financial_integrity-relevant thread, though no CW-specific implementing text for the travel rule was retrieved this cycle.

#### Outlook

The most consequential open question is whether the CGA&#x27;s crypto policy guideline itself, or a fuller VASP Act implementing text, becomes available in primary-source form in a future cycle, which would allow firmer characterisation of both the wallet-segregation regime and the token-classification and cross-border-transfer questions that remain thin this cycle. The phased timetable for full blockchain-analytics and wallet-segregation compliance runs to June 2027, giving a clear marker for the next material development window in the gambling-sector crypto-controls thread specifically.

Read full brief · 726 words

Key regulatory facts for Curaçao Regulatory Dimension Curaçao Standing Position

Jurisdiction Curaçao (CW)

Regulatory Scope Crypto & Digital Asset Regulation (8 modules, 22 sourced findings)

Crypto Licensing The Cayman Islands regulates virtual asset businesses under the Virtual Asset (Service Providers) Act, 2020 (VASPA), administered by the Cayman Islands Monetary Authority (CIMA).

Token Classification VASPA regulates by activity (exchange, transfer, custody, administration, issuance-related services) rather than through a MiCA-style differentiated token taxonomy.

On-Chain Activity Regime No CIMA guidance or Cayman statutory text specific to staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization was located in this research pass.

Stablecoin Regime No bespoke Cayman Islands stablecoin-specific issuance authorisation, reserve requirement, redemption right, disclosure, or systemic designation framework was identified in this research pass.

Primary Instruments Cited CoinDesk, CoinDesk, CoinDesk, Centrale Bank van Curacao en Sint Maarten (CBCS), CBCS

Last Confirmed / Updated 2026-10-25 (27 sources in cumulative register)

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### Curaçao: C1 Crypto LicensingAmberEnacted in forceModule confidence: Probable&#9662;

The Cayman Islands regulates virtual asset businesses under the Virtual Asset (Service Providers) Act, 2020 (VASPA), administered by the Cayman Islands Monetary Authority (CIMA). VASPA originally established a phased registration/notification regime (Phase One, effective October 2020) followed by licensing for higher-risk activities. In 2025, the Virtual Asset (Service Providers) (Amendment) Regulations extended mandatory CIMA licensing specifically to virtual asset custody and trading platform businesses, effective 1 April 2025, with a transitional filing deadline of 29 June 2025 for incumbents. Existing CIMA-regulated entities may in some cases operate under a waiver rather than separate VASPA registration.

Open gap — crypto-int-1 Full text of the National Ordinance on the Supervision of Virtual Asset Service Providers and its implementing licensing rules has not been retrieved; licensing-route detail, fees and prudential-capital figures remain unconfirmed. no under-indexing note recorded

Open gap — crypto-int-2 No CW-specific VASP enforcement-penalty provision has been located. no under-indexing note recorded

#### Crypto Licensing

Curacao&#x27;s virtual-asset licensing framework rests on the Landsverordening toezicht virtuele activa dienstverleners (VASP Act), enacted 13 March 2025 and brought into force via a Landsbesluit dated 24 June 2025. Under the Act, virtual asset service providers operating in or from Curacao require licensing or registration with the Centrale Bank van Curacao en Sint Maarten (CBCS), which functions as the sole supervisory authority for this activity class. This is a confirmed, in-force requirement, evidenced directly by the Curacao Government Gazette&#x27;s own publication of the ordinance&#x27;s entry into force, and it represents a material shift from the jurisdiction&#x27;s prior unregulated treatment of virtual-asset service provision.

A secondary, less firmly evidenced detail concerns the transitional path to this regime: reporting describes the VASP Act as replacing a 2024 mandatory-registration-only phase with the current, fuller licensing structure. This detail carries probable rather than confirmed confidence, since it rests on a single T3 secondary source rather than a primary CBCS or gazette document, and it should be read with that caveat. What is confirmed by the primary gazette source is simply that the Act is enacted and in force as of 24 June 2025, with CBCS as supervisor.

Outside this licensing core, several adjacent questions remain genuinely open rather than resolved. No CW-specific statutory token-classification taxonomy was located this cycle, and no on-chain-activity-specific rules covering staking, DeFi, mining or validator operations were found. The VASP Act&#x27;s framing suggests alignment with FATF Recommendation 15 on the travel rule, but no Curacao-specific implementing text for that requirement was retrieved. These are honestly recorded as research gaps for this cycle rather than as findings of regulatory absence — the underlying law may address them in text not yet retrieved.

#### Outlook

The CBCS licensing/registration track for VASPs is now the settled entry point for any crypto-asset business seeking to operate from or in Curacao, and that structural position is unlikely to shift materially in the near term. The open item to watch is whether primary-source text of the VASP Act itself, or CBCS implementing guidance, surfaces in a future cycle to resolve the token-classification, on-chain-activity, and travel-rule implementation questions that remain thin. Until then, an operator or counterparty assessing Curacao crypto exposure should treat the licensing requirement itself as settled and confirmed, while treating the surrounding operational detail as still-developing.

Read full sub-brief · 383 words Periodic update · new data 2026-10-04

#### Crypto Licensing

Curacao&#x27;s crypto-licensing framework is anchored in the National Ordinance on Providers of Services related to Virtual Assets (2023), which has been in force since 1 July 2025 and prohibits professional or commercial provision of virtual-asset services in or from Curacao without a prior licence from the Centrale Bank van Curacao en Sint Maarten (CBCS). Two narrower statuses sit outside the core licensing requirement: an exemption for institutions already licensed by CBCS under other frameworks, and a dispensation route available to qualifying foreign providers. The regime regulates virtual-asset activity on an activity-by-activity basis rather than through a token-category taxonomy.

The development this cycle is on the enforcement side rather than the licensing-scope side. CBCS has publicly stated that it is strengthening its enforcement posture against unlicensed financial-service and virtual-asset activity, with tools including penalty payments, administrative fines, and public warnings, and has indicated it may now issue simultaneous corrective orders and administrative fines rather than sequencing them. This posture shift is dated from CBCS&#x27;s internal structural reorganisation effective 1 January 2026. No specific fine amounts, case outcomes, or named enforcement targets for VASP-specific breaches have been located this cycle; the statement is a declared enforcement posture rather than a confirmed enforcement record. Licensed VASPs separately carry operating duties under the Ordinance, including a virtual-asset order-and-custody policy, conflicts-of-interest management, recovery-and-wind-down planning, security controls, and strong-authentication requirements, though no specific custody-loss liability cap has been identified.

The regime remains comparatively young, having been in force for fifteen months at the time of this cycle, and the enforcement-record depth needed to assess practical application of the strengthened posture is not yet available.

#### Outlook

Watch for the first confirmed enforcement case, fine amount, or named target under CBCS&#x27;s strengthened posture, which would move the current Probable-confidence enforcement signal to a firmer footing. No further licensing-scope change is indicated at this time.

Sources and findings (8)
- T3[CoinDesk](https://www.coindesk.com/policy/2020/11/02/cayman-islands-announces-legal-framework-in-bid-to-attract-crypto-businesses) — VASPs already working in the Cayman Islands, or planning to, must notify and register with the Cayman Islands Monetary Authority (CIMA) and comply with AML/CFT rules under Phase One of the virtual assets framework, effective 28 October 2020.
- T3[CoinDesk](https://www.coindesk.com/policy/2025/03/10/cayman-islands-now-requires-licensing-for-crypto-custody-and-trading-companies) — Under the Virtual Asset (Service Providers) (Amendment) Regulations, virtual asset custody and trading platform businesses operating in or from the Cayman Islands must obtain a CIMA license, effective 1 April 2025.
- T3[CoinDesk](https://www.coindesk.com/policy/2025/03/10/cayman-islands-now-requires-licensing-for-crypto-custody-and-trading-companies) — Firms already operating virtual asset custody or trading businesses in the Cayman Islands were required to submit their CIMA license applications by 29 June 2025 under a transitional filing window tied to the 2025 amendment regulations.
- T3[Centrale Bank van Curacao en Sint Maarten (CBCS)](https://www.buybitcoinsmart.com/curacao) — registration before offering professional or commercial virtual-asset services in or from Curacao
- T3[CBCS](https://www.curacaochronicle.com/post/unknown/cbcs-strengthens-crackdown-on-unlicensed-financial-service-providers) — A statutory VASP licensing regime (distinct from mere registration) is cited by secondary sources as effective from 1 July 2025, administered by the CBCS, with exemption for already-licensed eligible institutions and a dispensation route for qualifying foreign providers
- T1[CBCS](https://sky7.com/jurisdictions/curacao) — Non-compliance with mandatory LID/MOT registration obligations may result in legal consequences and sanctions for the institution; no specific fine schedule located

### Curaçao: C2 Token ClassificationAmberEnacted in forceModule confidence: Probable&#9662;

VASPA regulates by activity (exchange, transfer, custody, administration, issuance-related services) rather than through a MiCA-style differentiated token taxonomy. Security-type tokens and related dealing/advisory activity appear to fall under the separate Securities Investment Business Act (SIBA) framework, evidenced by crypto firms holding both VASP registration and a distinct Cayman securities investment business license. No CIMA-specific classification guidance for stablecoins, e-money tokens, asset-referenced tokens or NFTs was identified in this pass.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-10-25

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### Curaçao: C3 On-Chain Activity Regime unpopulated &#9662;

No CIMA guidance or Cayman statutory text specific to staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization was located in this research pass. VASPA&#x27;s licensing scope (custody, exchange/trading platforms) is the closest analog but does not explicitly enumerate these on-chain activities in the secondary sources reviewed. This module is being emitted with an explicit research gap pending direct access to CIMA rulebooks or the Cayman legislation portal.

Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded in this cycle

### Curaçao: C4 Stablecoin RegimeRedEnacted in forceModule confidence: Probable&#9662;

No bespoke Cayman Islands stablecoin-specific issuance authorisation, reserve requirement, redemption right, disclosure, or systemic designation framework was identified in this research pass. Stablecoins used as part of a VASP&#x27;s exchange/custody/transfer services would likely fall under general VASPA licensing, but no CIMA stablecoin-specific rulebook was located.

Horizon · 2026-09-30 (± a quarter) CGA crypto-policy compliant policy upload deadline Adopted, not yet in force · Tier 2 source

Horizon · 2027-06-30 (± six months) CGA crypto-policy full compliance deadline Adopted, not yet in force · Tier 2 source

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-10-25

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### Curaçao: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable&#9662;

CIMA&#x27;s licensing gatekeeping function for VASPs incorporates consumer protection and market confidence considerations, as demonstrated in a contested license rejection where CIMA cited risk to consumer protection and market confidence as grounds for refusal. The SEC-CIMA supervisory cooperation MOU also identifies investor protection as a shared regulatory objective for cross-border regulated entities. No dedicated marketing-restriction, custody-segregation, or complaint-handling rulebook specific to virtual asset consumers was independently confirmed in this pass.

Open gap — crypto-int-3 Exact commencement date of the CGA crypto-payment compliance rule for B2C gambling licensees (mid-2027 full-compliance deadline) is not confirmed. no under-indexing note recorded

Horizon · 2026-12-31 (± a quarter) CGA crypto risk-assessment and wallet-controls deadline Adopted, not yet in force · Tier 2 source

Horizon · 2027-Q2 (± six months) CGA crypto-payment compliance deadline for B2C gambling licensees Adopted · Tier 3 source

#### Consumer Protection

The consumer-protection-relevant crypto development for Curacao this cycle is sector-specific rather than general: the Curacao Gaming Authority&#x27;s crypto policy guideline, effective June 2026, requires licensed gambling operators to maintain strict segregation between player, operational and treasury crypto wallets, and prohibits the use of personal or owner-linked wallets for licensee transactions. This is a probable-confidence finding, resting on a single T2 trade-press source describing the guideline&#x27;s requirements, and it should be understood as a gambling-sector custody control rather than a jurisdiction-wide crypto consumer-protection framework.

A related signal from the same guideline is a stated preference for fiat-backed stablecoins over other token types for gambling-sector crypto transactions, with additional risk assessment required where operators use other token types. Again, this is a sector-specific disclosure and risk-management posture tied to the gambling regulator&#x27;s guideline rather than a general Curacao position on stablecoin consumer protection, and it carries the same probable confidence and single-source T2 caveat as the wallet-segregation finding.

Both findings sit at a genuine overlap point with the advennt monitor, which owns the substantive gambling-regulation analysis of the CGA&#x27;s guideline; this crypto-consumer-protection module records the crypto-specific custody and asset-preference dimensions of that same guideline without duplicating advennt&#x27;s licensing-and-enforcement framing. No general, non-sector-specific Curacao crypto consumer-protection regime — covering, for example, retail crypto exchange users outside the gambling context — was located this cycle.

#### Outlook

The practical question for the near term is whether the CGA guideline&#x27;s wallet-segregation and stablecoin-preference requirements are followed by comparable general-market crypto consumer-protection rules from CBCS covering non-gambling VASP customers. Nothing in this cycle&#x27;s evidence base indicates that such general rules exist yet. Confirmation of the primary CGA guideline text itself, rather than secondary trade-press description, would also usefully firm up the confidence level on both findings recorded here.

Read full sub-brief · 293 words Periodic update · new data 2026-10-25

#### Consumer Protection

The Curacao Gaming Authority has moved to restrict how its licensed online-gambling operators may interact with crypto-assets. Under the reported rule, CGA-licensed operators are prohibited from performing exchange or virtual-asset-service-provider activity themselves; they may accept crypto-assets solely as a payment method for gambling transactions, not as a basis for offering exchange, conversion or custody services to customers under the gambling licence. Full operational compliance with this restriction is required by mid-2027. The exact date on which the underlying rule itself took effect has not been confirmed in available sourcing, and the commencement date and the mid-2027 compliance deadline should not be treated as the same date: one is understood as a deadline for operators to achieve full compliance, while the date the rule itself was enacted or came into force is a separate and currently unconfirmed fact.

The consumer-protection rationale for this kind of restriction is reasonably legible even without further primary-source detail: separating a gambling operator&#x27;s payment-acceptance function from an exchange or custody function reduces the risk that a licensee uses its gambling licence as a basis for offering unregulated crypto-exchange services to its customer base, and limits the commingling of player funds with exchange-type holdings. This sits within a broader pattern, evident across CGA&#x27;s recent public communications, of the regulator reassessing how its licensees are permitted to operate following scrutiny of its own licensing infrastructure.

Available sourcing for this restriction is secondary-industry reporting rather than a primary CGA or CBCS instrument; the precise legal text, the rule&#x27;s own commencement date, and any transitional or enforcement provisions attached to the mid-2027 deadline have not been retrieved. This leaves genuine uncertainty about scope, for example whether the prohibition applies to exchange activity conducted through an affiliated but separately licensed entity, and about how compliance will be assessed or enforced once the mid-2027 deadline is reached.

#### Outlook

The principal marker to watch is publication of the underlying CGA or CBCS instrument text, which would resolve both the commencement-date question and the precise scope of the exchange-activity prohibition. In the absence of that text, the restriction should be treated as probable but not yet fully specified, with the mid-2027 deadline standing as the clearest confirmed marker currently available for when full operational compliance is expected.

1 earlier distinct update(s) Periodic update · new data 2026-10-18

#### Consumer Protection

The consumer-protection-relevant crypto development this cycle is custody segregation rather than disclosure. CGA-licensed gambling operators accepting crypto must now segregate assets into player-flow, operational and treasury wallets, and are barred from holding crypto in personal or beneficial-owner-linked wallets. Operators are also barred from providing custody or exchange services to players outside the gambling transaction itself, meaning a licensee cannot function as a de facto wallet or exchange provider for its player base. This is a sectoral gambling-specific control issued by the CGA, not a general VASP consumer-protection rule from the CBCS, and no general VASP-level custody or segregation standard has been identified this cycle. The rule is enacted but not yet effective, sitting on the same phased compliance timeline as the stablecoin-preference guideline: risk assessments and wallet controls are due by 31 December 2026, with full compliance required by 30 June 2027.

#### Outlook

The practical consumer-protection question going forward is how strictly the CGA audits wallet segregation once the December 2026 deadline passes, particularly given the same regulator is currently managing the operational disruption from its licensing-portal closure. No general VASP consumer-protection framework beyond this sectoral overlay has been located.

Sources and findings (5)
- T2[U.S. Securities and Exchange Commission](https://www.sec.gov/about/offices/oia/oia_bilateral/cayman-mou.pdf) — The SEC-CIMA cooperation framework identifies investor protection as a shared regulatory objective relevant to oversight of cross-border regulated entities, including Cayman-domiciled investment/crypto businesses.
- T2[Curaçao Gaming Authority](https://news.bitcoin.com/curacao-orders-its-crypto-casinos-to-screen-wallets-and-ban-mixers-with-full-compliance-due-in-2027/) — CGA-licensed gambling operators must segregate crypto assets into player-flow, operational and treasury wallets, may not hold crypto in personal or UBO-linked wallets, and may not provide custody or exchange services to players outside gambling transactions
- T3[National Ordinance on Providers of Services related to Virtual Assets (2023)](https://sky7.com/jurisdictions/curacao) — The VASP law imposes operating duties including a virtual-asset order-and-custody policy, conflicts-of-interest management, recovery-and-wind-down planning and security controls, alongside strong-authentication requirements, on licensed VASPs.
- T3[Curacao Gaming Authority (CGA)](https://sigma.world/news/cryptocurrencies-curacao-igaming/) — CGA-licensed gambling operators from performing exchange/VASP activity; crypto permitted only as a gambling payment method

### Curaçao: C6 Tax TreatmentGreenEnacted in forceModule confidence: Probable&#9662;

The Cayman Islands maintains a general zero direct-taxation regime applicable to all entities, including crypto asset businesses: no tax on income, capital gains, or dividend withholding. No Cayman-specific crypto tax statute (e.g., VAT/GST or a dedicated crypto reporting-obligation instrument) was identified; the general zero-tax framework is assumed to extend to crypto activity absent a carve-out.

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 3 traced claims · Re-verified 2026-10-25

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### Curaçao: C7 Cross-Border TransferGreenEnacted in forceModule confidence: Probable&#9662;

The Cayman Islands imposes no general exchange control or currency restrictions, which extends to the movement of crypto assets absent a specific statutory carve-out. No crypto-specific outbound restriction, sanctions-nexus rule, or reporting-threshold instrument was independently identified. Cross-border supervisory cooperation (e.g., CIMA-ADGM FSRA enforcement collaboration, and the SEC-CIMA MOU) exists at the regulator level but this is not a claim under this module&#x27;s enum (captured as disambiguation context in aml_cft_regime and consumer_protection).

Horizon · 2027-Q2 (± six months) CGA crypto guideline full-compliance milestone Adopted, not yet in force · Tier 3 source

Periodic update · new data 2026-10-18

#### Cross-Border Transfer

The cross-border-relevant development this cycle is narrow but specific: CGA-licensed gambling operators are now prohibited from accepting digital assets that originate from internationally sanctioned mixers, tumblers, or sanctioned wallets. This functions as a sanctions-nexus control applied at the point of a gambling transaction, rather than a general cross-border transfer rule applicable to all VASPs operating in or from Curacao. It is enacted but not yet effective, following the same phased timeline as the related stablecoin-preference and wallet-segregation rules, with full compliance due by 30 June 2027. No broader statutory cross-border transfer regime for crypto generally, covering matters such as outbound transfer reporting or correspondent-exchange due diligence beyond the gambling sector, has been identified this cycle.

#### Outlook

The sanctions-nexus prohibition will become fully binding alongside the other CGA crypto-policy obligations by 30 June 2027. Whether this sectoral control is extended to, or mirrored by, a general CBCS-administered cross-border transfer rule for non-gambling VASPs remains unconfirmed.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-10-25

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### Curaçao: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable&#9662;

Crypto AML/CFT obligations for JID=CW are governed by the FIM aml_ctf module and are intentionally not independently assessed or claimed in this crypto baseline to avoid duplicate ownership. For disambiguation only: Cayman Islands VASPs are subject to AML/CFT supervision by CIMA, and the Cayman Islands underwent CFATF/FATF mutual evaluation and was subsequently removed from the FATF increased-monitoring list in October 2023. Direct collaboration between CIMA and the Abu Dhabi Global Market Financial Services Regulatory Authority has also been cited by FATF as an example of cross-border VASP enforcement cooperation. No aml_cft_regime claims are produced here; see FIM.

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25

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