Cryptoassets Regulatory Intelligence cryptoassets.gi
GG-ALD v13.3.0
content: ai_generated legal review: never_reviewed (informational) publication gate: 2 failing5 sources retrieved model claude-sonnet-5 · 2026-10-03

GG-ALD

GG-ALD schema crypto-v2.0.0 trajectory: not yet assessedregulatedoverlaps: FIM, Advennt

Last updated · 8 categories · 38 sourced findings · 14 sources in the cumulative register

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Jurisdiction lead brief

Latest update · 18 October 2026

Lead Signal

The Guernsey Financial Services Commission has narrowed the VASP licensing perimeter applicable to the Bailiwick, including Alderney: as of 9 September 2026, with effect from 1 October 2026, the GFSC removed the blanket requirement for a firm already licensed by the Commission to obtain a separate virtual asset service provider licence, and it lifted the restriction that had prevented VASPs from serving retail customers. This is a liberalising move on two fronts at once -- it reduces duplicate licensing burden for already-regulated firms moving into crypto-asset activity, and it opens the retail segment to VASPs that were previously confined to institutional or professional counterparties. No Alderney-specific crypto-asset or VASP instrument exists distinct from this Bailiwick-wide regime; the Alderney Gambling Control Commission's own published scope confirms it regulates eGambling only and has no crypto-asset remit, so the GFSC change is the operative law for any VASP activity touching Alderney.

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#

The Bailiwick of Guernsey (Guernsey, Alderney and Sark treated as one regulatory unit for financial-services licensing) operates a Virtual Asset Service Provider (VASP) licensing regime under the Lending, Credit and Finance (Bailiwick of Guernsey) Law, which entered into force in July 2023 and is administered by the Guernsey Financial Services Commission (GFSC). There is no Alderney-specific crypto-asset licensing authority distinct from the GFSC. Alderney does, however, have its own sectoral gambling regulator, the Alderney Gambling Control Commission (AGCC), which licenses eCasinos under the Alderney eGambling Ordinance and Alderney eGambling Regulations 2009 but which has no remit over virtual-asset service provision as such. As of the most recent MONEYVAL assessment only one VASP was licensed Bailiwick-wide, a proof-of-concept reinsurance-linked token project restricted to institutional and wholesale clients, with demand for further licences expected to remain low.

Standing sub-brief · as of 11 October 2026264 words · last cycle 2026-10-18

Crypto Licensing

The Bailiwick of Guernsey, of which Alderney is part, requires a Part III licence from the GFSC for exchanging, transferring, safeguarding or administering virtual assets from within the Bailiwick, unless a Class Exemption applies. This requirement, under section 17 of the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022, has been in force since 1 July 2023 and remains the operative licensing gateway for virtual-asset activity in Alderney.

Periodic update · new data 2026-10-18

Crypto Licensing

The Guernsey Financial Services Commission regulates virtual asset service provider activity touching the Bailiwick of Guernsey, including Alderney, under the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022, as amended by the Lending, Credit and Finance (Amendment) Rules, 2026. On 9 September 2026 the Commission announced two changes to that regime, both effective 1 October 2026: it removed the blanket requirement for a firm already licensed by the Commission in another capacity to obtain a separate VASP licence, and it lifted the restriction that had previously confined VASPs to non-retail counterparties, allowing VASPs to serve retail customers. Both changes move in a liberalising direction, reducing duplicate licensing burden for existing licensees extending into crypto-asset activity and widening the addressable customer base for VASPs generally.

No instrument specific to Alderney, distinct from this Bailiwick-wide GFSC regime, has been found. The Alderney Gambling Control Commission's own published scope statement confirms that AGCC regulates eGambling exclusively and has no crypto-asset or VASP remit, which means the GFSC regime is the entire operative licensing framework for any VASP activity with an Alderney nexus; there is no parallel or supplementary Alderney-specific authorisation layer sitting alongside it. Whether incorporation in Alderney specifically, as opposed to incorporation elsewhere in the Bailiwick, carries any distinct supervisory treatment for a VASP applicant has not been confirmed either way.

Outlook

The narrowed perimeter is now in force. The next material marker for this module is confirmation, if any becomes available, of whether Alderney incorporation attracts distinct GFSC supervisory treatment for VASP applicants relative to Guernsey incorporation -- a question the Commission has not yet addressed on present evidence.

Sources and findings (9)
  1. T2 · FATF / MONEYVALFATF / MONEYVAL — A VASP licensing regime was introduced under the Lending, Credit and Finance Law applicable across the Bailiwick of Guernsey (including Alderney), with the licensing regime entering into force in July 2023.retrieved M5bindingin force
  2. T2 · FATF / MONEYVALFATF / MONEYVAL — As at the most recent national risk assessment, only one VASP was licensed in the Bailiwick of Guernsey (a proof-of-concept project set up by a re-insurance company providing insurance-linked virtual-asset tokens), and demand for further VASP licences was expected to remain low.retrieved M3non-binding
  3. T2 · FATF / MONEYVALFATF / MONEYVAL — The GFSC is the licensing and supervisory authority for VASPs (and all other Bailiwick financial-services businesses, TCSPs and dealers in bullion), applying Bailiwick-wide including Alderney.retrieved M4bindingin force
  4. T2 · FATF / MONEYVALFATF / MONEYVAL — The AGCC is the authority tasked with the licensing of eCasinos in Alderney; it has no licensing remit over virtual-asset service providers, which remain exclusively a GFSC matter.retrieved M3bindingin force
  5. T2 · FATF / MONEYVALFATF / MONEYVAL — The AGCC relies almost exclusively on remedial actions for AML/CFT and licensing breaches in the eGambling sector and, during the MONEYVAL review period, never exercised its formal enforcement powers.retrieved M3non-binding
  6. T2 · FATF / MONEYVALFATF / MONEYVAL — The GFSC holds wide-ranging remediation and enforcement powers across all Bailiwick-regulated sectors, including VASPs, and has exercised enforcement action against both regulated entities and senior officers, although the number of pecuniary fines imposed remains low relative to the volume of supervisory engagements.retrieved M3bindingin force
  7. T2 · FATF / MONEYVALFATF / MONEYVAL — No specific GFSC or AGCC enforcement action against a named crypto/VASP firm in Alderney or the wider Bailiwick was identified in this research pass; recency-window enforcement detail (authority, firm, amount, provision breached) could not be confirmed.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
  8. T2 · FATF / MONEYVALFATF / MONEYVAL — No explicit transitional or grandfathering period (comparable to MiCA Art.143(3)) for firms operating before the July 2023 VASP licensing regime was identified in the sources reviewed.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
  9. T2 · FATF / MONEYVALFATF / MONEYVAL — No VASP-specific own-funds, minimum capital, or overheads-based prudential capital requirement (comparable to MiCA Art.67/Annex IV) was identified for Bailiwick-licensed VASPs in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

No bespoke statutory token taxonomy equivalent to MiCA's asset-referenced-token / e-money-token / utility-token categories was identified for the Bailiwick of Guernsey. VASP scope is instead captured functionally through the FATF-aligned 'virtual asset' / 'virtual asset service provider' concept embedded in the Lending, Credit and Finance Law, rather than through a category-by-category classification regime.

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

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T2 · FATF / MONEYVALFATF / MONEYVAL — The Bailiwick's regulatory net for crypto-assets operates on a functional VASP-activity basis (exchange, transfer, safekeeping/administration, and participation in an issuer's offer/sale) rather than on a discrete token-category taxonomy; no separate security-token, e-money-token, asset-referenced-token, or NFT-specific classification rule was located for Guernsey/Alderney.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

No Guernsey/Alderney-specific rules governing staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization were identified in this research pass. Any such activity conducted as a business for or on behalf of a third party would likely fall within the functional VASP licensing net under the Lending, Credit and Finance Law, but no dedicated guidance confirming this was located.

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

no periodic updates on record for this sub-brief

Sources and findings (7)
  1. T2 · FATF / MONEYVALFATF / MONEYVAL — No staking-specific rule was identified for the Bailiwick of Guernsey.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
  2. T2 · FATF / MONEYVALFATF / MONEYVAL — No DeFi-lending-specific rule was identified for the Bailiwick of Guernsey.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
  3. T2 · FATF / MONEYVALFATF / MONEYVAL — No decentralized-exchange-specific rule was identified for the Bailiwick of Guernsey.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
  4. T2 · FATF / MONEYVALFATF / MONEYVAL — No crypto-mining-specific rule was identified for the Bailiwick of Guernsey.retrieved M1non-bindingour coverage gap, expected to resolve on a re-run
  5. T2 · FATF / MONEYVALFATF / MONEYVAL — No node-operation-specific rule was identified for the Bailiwick of Guernsey.retrieved M1non-bindingour coverage gap, expected to resolve on a re-run
  6. T2 · FATF / MONEYVALFATF / MONEYVAL — No validator-activity-specific rule was identified for the Bailiwick of Guernsey.retrieved M1non-bindingour coverage gap, expected to resolve on a re-run
  7. T2 · FATF / MONEYVALFATF / MONEYVAL — No general tokenization-specific rule was identified for the Bailiwick of Guernsey, beyond the fact that the sole licensed VASP's business model involves insurance-linked virtual-asset tokens.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run

#

No Guernsey/Alderney-specific statutory stablecoin or e-money-token regime comparable to MiCA Title III/IV or EMD2 was identified. The Bailiwick is outside both the EU (MiCA) and UK statutory perimeters, and no local issuer-capital, reserve-backing, redemption, disclosure, or systemic-designation rule for fiat- or asset-referenced tokens was located in this research pass.

Standing sub-brief · as of 11 October 2026167 words · last cycle 2026-10-11

Stablecoin Regime

The GFSC confirmed, in a statement marking the first anniversary of its Digital Finance Initiative on 14 September 2026, that it is progressing work on a dedicated regulatory framework for stablecoins, with feedback and rules expected during Autumn 2026. This framework would sit alongside a separate, earlier-stage proposal to remove stablecoins from general virtual-asset treatment altogether, reclassifying them under their own regulatory category rather than folding them into the Part III VASP regime that governs other virtual-asset activity in the Bailiwick.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T2 · FATF / MONEYVALFATF / MONEYVAL — No stablecoin/e-money-token issuance-authorisation regime was identified for the Bailiwick of Guernsey.retrieved M3non-bindinga fact about the regime
  2. T2 · FATF / MONEYVALFATF / MONEYVAL — No stablecoin reserve-asset backing requirement was identified for the Bailiwick of Guernsey.retrieved M3non-bindinga fact about the regime
  3. T2 · FATF / MONEYVALFATF / MONEYVAL — No statutory stablecoin holder redemption right was identified for the Bailiwick of Guernsey.retrieved M3non-bindinga fact about the regime
  4. T2 · FATF / MONEYVALFATF / MONEYVAL — No stablecoin-specific disclosure regime was identified for the Bailiwick of Guernsey.retrieved M2non-bindinga fact about the regime
  5. T2 · FATF / MONEYVALFATF / MONEYVAL — No systemic-stablecoin designation mechanism was identified for the Bailiwick of Guernsey.retrieved M2non-bindinga fact about the regime
  6. T2 · FATF / MONEYVALFATF / MONEYVAL — No stablecoin/e-money-token issuer capital regime was identified for the Bailiwick of Guernsey.retrieved M3non-bindinga fact about the regime

#

Beyond the Bailiwick's general conduct-of-business framework applicable to all GFSC-licensed financial-services firms, no crypto-specific consumer-protection rules (custody segregation, marketing restrictions, market-abuse regime, complaint-handling deadlines, or order-handling/conflicts rules) specific to VASPs were identified in this research pass. The sole licensed VASP is restricted to servicing institutional and wholesale clients only, which the Bailiwick's own 2024 risk re-analysis cites as a factor limiting retail-facing consumer-protection exposure.

Standing sub-brief · as of 11 October 2026194 words · last cycle 2026-10-11

Consumer Protection

The blanket restriction preventing virtual-asset service providers in the Bailiwick, including Alderney, from serving retail customers was lifted effective 1 October 2026. Retail access is now assessed case by case rather than excluded as a category. Prior to this date, VASPs operating under the GFSC's Part III regime served only institutional or wholesale counterparties, meaning this change represents a structural broadening of who a licensed VASP in Alderney may serve.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T2 · FATF / MONEYVALFATF / MONEYVAL — No VASP-specific custody/safeguarding or client-asset-segregation rule (comparable to MiCA Art.75) was identified for the Bailiwick of Guernsey.retrieved M4non-bindingour coverage gap, expected to resolve on a re-run
  2. T2 · FATF / MONEYVALFATF / MONEYVAL — No crypto-promotion-specific marketing-restriction rule was identified for the Bailiwick of Guernsey in this pass; general Bailiwick financial-promotion rules under the Protection of Investors Law may apply but crypto-specific application was not confirmed.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
  3. T2 · FATF / MONEYVALFATF / MONEYVAL — No crypto-specific market-abuse regime (comparable to MiCA Title VI) was identified for the Bailiwick of Guernsey.retrieved M3non-bindinga fact about the regime
  4. T2 · FATF / MONEYVALFATF / MONEYVAL — No VASP-specific complaint-handling procedure, response deadline, or ombudsman-access rule was identified for the Bailiwick of Guernsey in this pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
  5. T2 · FATF / MONEYVALFATF / MONEYVAL — The Bailiwick's sole licensed VASP is restricted to servicing only institutional and wholesale clients, a licence condition that the authorities cite as limiting the risk of VASP misuse and inherently removing retail suitability/appropriateness exposure for that licensee.retrieved M4bindingin force
  6. T2 · FATF / MONEYVALFATF / MONEYVAL — No VASP-specific best-execution, inducement, or conflicts-of-interest rule (comparable to MiCA Arts.72/78/80) was identified for the Bailiwick of Guernsey in this pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run

#

Guernsey-incorporated companies, including GFSC-licensed VASPs, are generally subject to the Bailiwick's standard 0% statutory corporate tax rate under its general company-tax regime. No crypto-specific income-tax, capital-gains, VAT/GST, withholding, or reporting-obligation guidance for virtual-asset transactions was identified in this research pass.

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

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T4 · SEC EDGARSEC EDGAR — A Guernsey-incorporated company (the corporate form typically used by a GFSC-licensed VASP) is subject to a statutory Guernsey corporate tax rate of zero percent, with any effective tax rate attributable to foreign taxes on non-Guernsey income.retrieved M3bindingin force
  2. T4 · SEC EDGARSEC EDGAR — No crypto-specific capital-gains tax rule for the Bailiwick of Guernsey was confirmed in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
  3. T4 · SEC EDGARSEC EDGAR — No crypto-specific VAT/GST treatment was confirmed for the Bailiwick of Guernsey in this research pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
  4. T4 · SEC EDGARSEC EDGAR — No crypto-specific withholding-tax rule was confirmed for the Bailiwick of Guernsey in this research pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
  5. T4 · SEC EDGARSEC EDGAR — No crypto-asset tax-reporting obligation (e.g. a CRS/DAC8-equivalent crypto-asset reporting framework) was confirmed for the Bailiwick of Guernsey in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

The Bailiwick of Guernsey (including Alderney) is a British Crown Dependency, sitting outside both the EU's MiCA regulatory/passporting perimeter and the UK's FCA cryptoasset regulatory perimeter. No passporting, equivalence, or mutual-recognition arrangement permitting a Bailiwick VASP licence to be used to access EU or UK markets (or vice versa) was identified in this research pass.

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

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T4 · SEC EDGARSEC EDGAR — Guernsey (and by extension the Bailiwick, including Alderney) is a British Crown Dependency in the Channel Islands, constitutionally and regulatorily separate from both the EU and the UK, meaning a Bailiwick VASP licence does not by itself confer EU MiCA or UK FCA market access.retrieved M3non-binding
  2. T2 · FATF / MONEYVALFATF / MONEYVAL — No Bailiwick-specific cross-border travel-rule mechanics (beyond the general FATF-aligned VASP framework) were confirmed for Guernsey/Alderney in this research pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
  3. T2 · FATF / MONEYVALFATF / MONEYVAL — No specific outbound-transfer restriction for Bailiwick VASPs dealing with foreign counterparties was confirmed in this research pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run
  4. T2 · FATF / MONEYVALFATF / MONEYVAL — No specific cross-border reporting threshold for Bailiwick VASP transfers was confirmed in this research pass.retrieved M2non-bindingour coverage gap, expected to resolve on a re-run

#

AML/CFT regulation of virtual-asset service provision in the Bailiwick of Guernsey is out of scope for this crypto-consumer baseline, since crypto subscribes to the financial-integrity (FIM) aml_ctf producer. For disambiguation only: the GFSC is the AML/CFT supervisor for all Bailiwick financial institutions and DNFBPs other than eCasinos (including VASPs), while the AGCC is the AML/CFT supervisor exclusively for eCasinos in Alderney, applying the Alderney eGambling Ordinance's Schedule 4 obligations (extended to counter proliferation financing in February 2024).

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

no periodic updates on record for this sub-brief

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Publication gate

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schema_validpass
source_tier_integrity_okpass
every_practical_object_has_source_idn/a — no subject in this jurisdiction
min_quoted_text_presentwaived — floor 0%
egress_verifiedpass
manual_overrideFAIL
jurisdiction_source_floor_metFAIL
tier_a_b_national_primary_pct20.0
aggregator_only_jurisdiction_count0

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