VASP License in Curacao

The regulation of cryptocurrencies in Curacao remains relatively nascent.

The government has stated that it is at the beginning of forming cryptocurrency regulation, with plans for future modifications to the laws as the legal framework continues to develop.

The enactment of the Landsverordening toezicht virtuele activa dienstverleners (VASP Act) on March 13, 2025, represents a definitive strategic pivot for Curacao, transforming the jurisdiction into an institutional-grade regulated hub.

Curacao law forms the foundation of this new regulatory regime, establishing the evolving legal framework for crypto businesses.

Curacao is also tied to the European Union through its association with the Netherlands, but not a Member State. This partly influences its regulatory environment and the development of its legal framework.

For global operators, this legislation is the primary mechanism for aligning with FATF Recommendation 15 standards, effectively mitigating the “de-risking” crisis that has historically severed crypto-native firms from traditional banking rails.

By replacing the 2024 mandatory registration phase with a rigorous licensing regime, Curacao provides the legal certainty required for long-term capital allocation and international expansion.

LegalBison designs the operational architecture and manages the full application process for obtaining a crypto license in Curacao. As a licensed Corporate Service Provider, the firm guides digital asset projects through local regulatory requirements, handling company formation, compliance program setup, and regulator liaison to obtain a Curacaoan VASP license.

Quick Facts: Curacao VASP

In the current global climate, regulatory clarity is a high-value competitive asset.

Curacao offers a sophisticated environment that balances technological innovation with traditional financial rigor.

• Legal Certainty through “Landsverordening”: Unlike temporary measures, the 2025 Act provides a permanent legislative foundation, protecting businesses from the volatility of “regulation by enforcement” seen in other jurisdictions;
• Central Bank Pedigree: The CBCS oversees a dual jurisdiction (Curacao and Sint Maarten). While the 2025 VASP Act is currently specific to Curacao, the involvement of a Central Bank that manages two financial systems adds significant regional prestige and professional standing to any license held;
• Cost-Effective and Fast Market Entry: The crypto license in Curacao offers a cost-effective and relatively fast entry point for crypto businesses into the global market;
• Legitimacy and User Trust: Operating with a government-issued license from Curacao provides legitimacy, which is critical for user trust and partnerships with banks;
• Tax Advantages: Curacao has no capital gains, dividend, or inheritance tax, making it attractive for entrepreneurs launching crypto projects;
• Lower Operational Costs: The operational costs of running a crypto business in Curacao are significantly lower compared to other jurisdictions, including licensing, office rent, employee wages, and compliance requirements, attracting startups and entrepreneurs.

The National Ordinance on the Supervision of Virtual Asset Service Providers (effective 2025) defines the main crypto activities that require a license to be performed by a company.

While there is a single license category, the obligations differ based on whether you intend:

• to operate a virtual assets exchange (exchanging between virtual assets and fiat, or between forms of virtual assets);
• to engage in the business of providing custody (safekeeping and administration) of virtual assets or access means.

Both of these activities require the payment of application and annual supervision fees, which are legally mandated to cover the Central Bank’s actual costs rather than a flat tax.

On the application side, what will differ is the specific operational compliance required by the regulator. In the case of a custodial company, requirements in terms of segregating client assets from the company’s own funds and liability for loss of assets due to hacks will be the most important.

The Ordinance also describes other types of activity that encompass transfer services and financial services related to the issuance and sale of virtual assets.

For companies willing to provide a new and innovative service, such as issuing their own token, the law provides a specific framework for Issuers. This specific regulation requires the publication of a “white paper” approved by the Bank to ensure the project acts honestly and professionally.

Furthermore, the Central Bank has the authority to grant exemptions or dispensations from certain rules if the applicant demonstrates that the objectives of the law are otherwise met, offering flexibility for unique business models.

Once the application is ready, the VASP applicant must pay a fee to the Central Bank (CBCS) which is legally mandated to be cost-neutral, covering only the actual expenses of the regulator.

To provide any Virtual Assets Service (including Custody or Exchange), the application fee is established by National Decree and charged immediately upon receipt of the application.

To maintain the license, the VASP must pay an annual supervision fee, the amount of which is calculated to equal at most the costs incurred by the Bank for exercising supervision.

These fees are based on direct and indirect costs incurred by the VASP applicant and may be adjusted annually based on the consumer price index.

This approach means there is no fixed sum applicable for all applicants, and that the CBCS decided to adapt its fee structure to the size and capacity of each applicant.

Curacao does not levy corporate income taxes on virtual assets service providers’ activities.

There are also no withholding taxes.

Dividends shall only be taxable in the residence country of the shareholder receiving a dividend payment.

Curaçao mandates a Risk-Based Approach (RBA).

The August 2024 Provisions & Guidelines (issued for Securities Intermediaries and Asset Managers) reflect the compliance pillars required under the National Ordinance on the Reporting of Unusual Transactions (MOT) and the National Ordinance on Identification when Rendering Services (LID), which also apply to VASPs:

• Customer Due Diligence (CDD): Verification of natural and legal persons is required before rendering services, including the mandatory identification of the Ultimate Beneficial Owner (UBO);
• Enhanced Due Diligence (EDD): Mandatory for high-risk clients, including Politically Exposed Persons (PEPs) and transactions involving FATF-listed high-risk jurisdictions or countries with strategic AML/CFT deficiencies;
• Transaction Monitoring: Continuous scrutiny is required to ensure activities align with the client’s risk profile and to verify the source of wealth and funds;
• Reporting Obligations: Any “Unusual Transaction” (or intended transaction) must be reported immediately to the Financial Intelligence Unit (FIU) under the MOT.

No, “there is no specific regulations for crypto in Curacao” is not true anymore.

Since 2025, Curacao regulates crypto companies as Virtual Assets Services Providers.

Most of the information found on the internet are critically outdated.

No, there are no relationships between the VASP framework and the Curacao Gaming Board.

The VASP regime is managed by the Central Bank of Curacao and Sint Maarten (CBCS).

The cryptocurrency regulation in Curaçao is now fully relying on the National Ordinance on the Supervision of Virtual Asset Service Providers (Landsverordening toezicht virtuele activa dienstverleners).

It details the requirements and obligations of cryptocurrency-related companies, to secure and maintain the Curaçao crypto license.

These requirements are tied to another set of laws, which are relative to anti-money laundering, countering terrorism financing, and combating financial crime:

• National Ordinance on Identification when Rendering Services (LID/NOIS);
• National Ordinance on the Reporting of Unusual Transactions (MOT/NORUT);
• Sanctions National Ordinance (Sanctielandsverordening) and the Kingdom Sanction Law (Rijkssanctiewet).

The regulations pertaining to crypto in Curaçao are therefore combining a dedicated law, the VASP supervision ordinance, and acts regarding AML-CFT and KYC.

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The Centrale Bank van Curaçao en Sint Maarten (CBCS) serves as the sole supervisory authority, possessing the exclusive mandate to oversee the market’s integrity and stability.

This guide is designed to assist C-suite executives and compliance architects in navigating the transition to the 2025 formal regime, ensuring that operational structures meet the high bar of Dutch-Caribbean regulatory scrutiny.

The VASP Act provides the CBCS with the legal mandate to govern the sector through a centralized, high-transparency model.

• Scope of Authority (Article 3): The CBCS holds the power to decide on licenses, exemptions (vrijstellingen), dispensations (ontheffingen), and permissions (toestemmingen). This comprehensive authority ensures no segment of the virtual asset market operates in a regulatory vacuum. In addition, the Curacao Gambling Authority (CGA) will be responsible for compliance and regulation of new crypto license holders, further strengthening oversight within the evolving legal framework.
• Evasion of Supervision (Article 10): A critical refusal ground for the CBCS is the “evasion clause.” Under Article 10(a), the Bank will refuse a license if it has grounds to believe the applicant is seeking a Curacao license specifically to evade supervision in another country.
• AML/CFT Integration: The Act is legally tethered to the National Ordinance on Identification (LID) and Reporting of Unusual Transactions (MOT). Licensees are functionally equivalent to traditional banks regarding their duties to combat money laundering and terrorism financing.
• The Public VASP Register (Article 18): Transparency is maintained through a public register of all licensed and exempted entities, providing global counterparties with a “ground truth” for verifying the regulatory status of Curacao-based firms.

Precise activity definitions are the bedrock of operational compliance.

Article 1 of the 2025 Act authorizes five core activities:

1. Fiat-to-Crypto Exchange: Exchanging between virtual assets and fiduciary (fiat) currency;
2. Crypto-to-Crypto Exchange: Exchanging between one or more forms of virtual assets;
3. Transfer Services: The transfer of virtual assets on behalf of third parties;
4. Custodial Services: The safekeeping or management of virtual assets or tools (private keys) to exercise control over them;
5. Financial Services for Issuance: Providing services related to the offer, purchase, or sale of virtual assets (e.g., Token Sales/ICOs).