Stablecoin issuer / redeemer in Antigua and Barbuda

Pakistan's central bank lifted a seven-year ban in April 2026, allowing banks to service crypto providers, reversing the restrictive framework of the 2020 Act.

Section 2 of the Act defines a "virtual asset" broadly as:

"a digital representation of value that can be digitally traded or transferred and used for payment or investment purposes but does not include digital representations of fiat currencies, securities and other financial assets that are already covered by traditional financial services legislation."

Stablecoins, by their nature of being a digital representation of value intended for payment or investment, fall squarely within this definition.

The Act does not explicitly carve out specific sub-classifications like "e-money tokens," "payment tokens," or "securities tokens" for stablecoins in the way some other jurisdictions do. Instead, the focus is on regulating the businesses that deal with these virtual assets.

Required. Any person carrying on a "virtual assets business" in or from Antigua and Barbuda must be licensed by the FSRC.

Section 4(1) states: "A person shall not carry on a virtual assets business in or from Antigua and Barbuda unless that person holds a valid licence issued by the Commission under this Act."

Section 3(1) defines "virtual assets business" to include activities like:

(f) issuance of virtual assets;

(e) participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset;

Issuing a stablecoin would fall under sub-section (f) "issuance of virtual assets" and likely (e) if there's an offer/sale component. Therefore, a stablecoin issuer would require a VABA license from the FSRC.

Licensing involves meeting certain prudential requirements, fit and proper tests for management, robust AML/CFT policies, and a clear business plan.

The Virtual Assets Business Act, 2020, does not explicitly stipulate specific reserve requirements for stablecoin issuers akin to a 1:1 fiat backing in Antigua & Barbuda.

Evidence fact ag.stablecoin.the-virtual-assets-business-act-2020 not found (may have been renamed).

The DABA requires a licensee to maintain capital sufficient to meet its liabilities and obligations.

The FSRC determines the specific minimum capital requirements, which can vary based on the type and scope of the digital asset business activities. Historically, capital requirements for various financial licenses in offshore jurisdictions can range from USD $100,000 to $250,000 or more, and for digital asset businesses, it's expected to be substantial to ensure solvency and protect clients. Applicants must demonstrate robust financial standing.

This is a cornerstone requirement, heavily influenced by FATF standards. Licensees must implement comprehensive Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) policies and procedures.

Customer Due Diligence (CDD): Robust KYC procedures for identifying and verifying clients (individuals and legal entities).

Ongoing Monitoring: Continuous monitoring of transactions and business relationships for suspicious activity.

Reporting: Reporting of suspicious transactions to the national Financial Intelligence Unit (FIU).

Sanctions Screening: Screening clients against national and international sanctions lists.

Record Keeping: Maintaining records for a specified period (typically 5 years).

Compliance with the Travel Rule for virtual asset transfers, now integrated under frameworks like MiCA, requires VASPs to obtain and transmit originator and beneficiary information, including standardized identifiers such as Legal Entity Identifiers (LEIs) where applicable, as part of evolving global regulatory infrastructure.

While not always a requirement for a physical office for all license types, entities generally need to establish a significant operational presence, which often includes a physical office, local management, and a registered agent in Antigua and Barbuda.

Key personnel, such as the Compliance Officer and Money Laundering Reporting Officer (MLRO), may be required to be resident in Antigua and Barbuda.

All directors, senior management, significant shareholders, and beneficial owners must undergo rigorous "fit and proper" assessments by the FSRC. This involves background checks, demonstrating competence, integrity, and sound financial standing.

Technology and Security:

Applicants must demonstrate that they have robust and secure IT systems, cybersecurity measures, data protection protocols, and business continuity plans to protect client assets and data. This includes cold storage solutions for large holdings of digital assets.

A comprehensive business plan outlining the intended operations, target market, risk management framework, internal controls, and corporate governance structure.

Initial application often requires audited financial statements (for existing businesses) and ongoing submission of audited financials is a licensing condition.

The correct name of the Antigua & Barbuda legislation is the Digital Assets Business Act, 2020 (as amended by the Digital Assets Business (Amendment) Act, 2020), not 'Digital Assets (Business) Act, 2020 (DAFIA)'.

Identification and Verification:

For Individuals: Obtain and verify identity using reliable independent sources (e.g., government-issued photo ID, proof of address, date of birth, nationality).

For Legal Persons/Arrangements (Companies, Trusts): Obtain and verify identity of the entity, its legal form, proof of existence, powers governing the entity, names of relevant persons (directors, trustees), and the beneficial owners (persons who ultimately own or control 25% or more of the entity).

Scrutinize transactions throughout the course of the relationship to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile.

Keep customer identification data, beneficial ownership information, and risk assessments up-to-date.

Apply risk-calibrated, continuous, and technology-driven Enhanced Due Diligence (EDD) for higher-risk customers, integrated into a dynamic control plane rather than a static checklist.

Politically Exposed Persons (PEPs) and their family members/close associates.

Customers from AG (Antigua and Barbuda) are from a jurisdiction under increased monitoring by FATF, but FATF policy explicitly prohibits de-risking or blanket exclusion of all customers from such jurisdictions, requiring instead a risk-based approach.

Transactions of a complex, unusually large, or unusual pattern.

Customers engaged in activities known to be susceptible to ML/TF.

VASPs must determine the source of funds and source of wealth for high-risk customers.

Sanctions Screening: Screen customers and transactions against national and international sanctions lists.

Reporting Obligation: If a VASP knows, suspects, or has reasonable grounds to suspect that funds are proceeds of a criminal activity, or are related to terrorist financing, it must promptly report this to the FIU. This applies regardless of the amount or whether the transaction is completed.

Corporate Income Tax: Corporations are subject to income tax on their profits.

Evidence fact ag.tax.no-crypto-specific-tax-reporting not found (may have been renamed).