Dominica

**No Dedicated VASP Licensing:** Dominica does not have specific laws or regulations for crypto exchanges, custody providers, or virtual asset payment processors.

**AML/CFT Oversight:** The primary regulatory angle for virtual asset businesses in Dominica is through existing Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) legislation, which views virtual assets as "funds" or "financial instruments" for reporting purposes.

**General Business Registration:** Companies engaging in crypto activities would typically register as a general business entity, such as an International Business Company (IBC), rather than applying for a crypto-specific license.

**Cryptocurrency Exchanges:** No specific crypto exchange license.

**Custody Providers:** No specific custody license for virtual assets.

**Payment Processors (Virtual Assets):** No specific license for processing payments in virtual assets.

**Offshore Banking Act:** For entities engaging in offshore banking activities.

**Money Services Business License:** If handling traditional fiat money remittances, currency exchange, etc.

**International Business Companies Act:** For general business registration as an IBC, which is often used by non-resident entities.

**Registration:** Companies conducting virtual asset activities would primarily register under the **International Business Companies Act** or the **Companies Act** for domestic entities. This is a corporate registration, not a financial services license specific to virtual assets.

**Licensing:** Specific financial services licenses (e.g., for banking, insurance, money services) are distinct from virtual asset activities unless those activities explicitly cross into regulated financial products or services under existing law.

**No specific capital requirements for virtual asset businesses.**

General IBC registration has no minimum capital requirement.

If a company were to obtain a *traditional* financial services license (e.g., offshore banking), significant capital requirements would apply.

This is the most critical area of compliance. All financial institutions and designated non-financial businesses and professions (DNFBPs) in Dominica are subject to the **Money Laundering Prevention Act**. Virtual asset businesses, even without a specific license, are expected to comply.

**Customer Due Diligence (CDD):** Implementing robust KYC procedures to identify and verify the identity of customers and beneficial owners.

**Record-Keeping:** Maintaining records of transactions and CDD information for a specified period (typically 5-7 years).

**Suspicious Transaction Reporting (STR):** Reporting suspicious activities to the Financial Intelligence Unit (FIU) of Dominica.

**Internal Controls:** Implementing internal policies, procedures, and training programs to combat money laundering and terrorist financing.

**Risk Assessment:** Conducting regular risk assessments related to ML/TF exposure.

The Financial Services Unit (FSU) is responsible for ensuring compliance with AML/CFT obligations across the financial sector.

**Registered Office/Agent:** An International Business Company (IBC) is required to maintain a registered office and a registered agent in Dominica. This is a statutory requirement for IBCs.

**No requirement for physical operational presence or local staff** specific to virtual asset activities, unless the business chooses to establish such a presence for operational reasons.

**Consult a Local Registered Agent:** Engage with a local registered agent or law firm in Dominica. They will guide you through the process and act as your statutory agent.

**Company Name Reservation:** Reserve the desired company name with the Companies and Intellectual Property Office (CIPO).

**Preparation of Incorporation Documents:** The registered agent will prepare the Memorandum and Articles of Association.

**Submission and Filing:** Submit the incorporation documents to CIPO.

**Issuance of Certificate of Incorporation:** Once approved, CIPO will issue a Certificate of Incorporation.

**Business Bank Account:** Open a corporate bank account (can be challenging for crypto businesses in many jurisdictions).

**Ongoing Compliance:** Ensure ongoing compliance with IBC regulations (e.g., annual returns) and, critically, AML/CFT obligations.

**The Financial Services Unit (FSU) Dominica:**

This is the primary regulator for financial services in Dominica and oversees AML/CFT compliance.

**Money Laundering Prevention Act, Chapter 10:10 (as amended):**

This is the foundational AML/CFT legislation that all financial sector participants, including virtual asset businesses (even if not explicitly named), are expected to comply with. It outlines CDD, record-keeping, and STR obligations.

**URL (Dominica Legal Information Institute - DOMINLII):** https://dominlii.org/content/money-laundering-prevention-act-chapter-1010-0

*Note: Always seek the most current consolidated version of the Act.*

**International Business Companies Act, Chapter 78:01 (as amended):**

This act governs the formation and operation of IBCs, the most common type of entity used by non-resident businesses in Dominica.

**Financial Intelligence Unit (FIU) Dominica:**

Receives and analyzes suspicious transaction reports.

**Regulatory Uncertainty:** The lack of specific virtual asset legislation means greater regulatory uncertainty. While it might seem attractive initially due to less red tape, it also means businesses operate in a gray area, which can pose risks for both the business and its customers.

**FATF Compliance:** Dominica, as a member of the Caribbean Financial Action Task Force (CFATF), is subject to the recommendations of the Financial Action Task Force (FATF). FATF Recommendation 15 specifically addresses virtual assets and VASPs, requiring countries to regulate and supervise VASPs for AML/CFT purposes. While Dominica may not have implemented a dedicated licensing regime yet, it is expected to comply with these recommendations over time. Future regulations are possible.

**Banking Access:** Obtaining traditional banking services can be extremely challenging for crypto-related businesses, regardless of the jurisdiction, due to perceived high AML/CFT risks.

**Money Laundering (Prevention) Act [Chapter 12:29]**: This is the core legislation that sets out the framework for preventing money laundering and terrorist financing. It defines predicate offences, outlines the obligations of financial institutions and DNFBPs, and establishes the Financial Intelligence Unit (FIU).

**Money Laundering (Prevention) Regulations**: These regulations provide more detailed rules and procedures for implementing the provisions of the Act, including specific requirements for customer due diligence, record-keeping, and reporting.

**Anti-Terrorism Act**: This legislation addresses the prevention and suppression of the financing of terrorism and related activities.

**Role**: The FSU is the primary regulatory and supervisory body in Dominica for non-bank financial institutions and designated non-financial businesses and professions (DNFBPs), which would include VASPs for AML/CFT purposes. It is responsible for overseeing compliance with AML/CFT legislation.

**Role**: The FIU of Dominica is the central national authority responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other financial information concerning suspected money laundering and terrorist financing to law enforcement agencies.

**Website**: http://fiu.gov.dm/ (While FSU and FIU are distinct, the FSU website often contains information or links relevant to the FIU's operations).

**Eastern Caribbean Central Bank (ECCB)**:

**Role**: As Dominica is a member of the Eastern Caribbean Currency Union, the ECCB plays a role in the broader financial system stability and can issue guidance or directives that impact all financial sector players, including those dealing with virtual assets, even if direct AML/CFT supervision for VASPs falls under the FSU.

**Identification and Verification of Customers**:

**Natural Persons**: Obtain and verify the customer's full name, residential address, date of birth, nationality, and an official identification document (e.g., passport, national ID card, driver's license).

**Legal Entities (Companies, Partnerships, Trusts)**: Obtain and verify the entity's name, legal form, proof of existence (e.g., certificate of incorporation), registered address, names of directors/partners, and the constitutive documents (e.g., articles of association).

**Beneficial Ownership**: Identify and verify the natural person(s) who ultimately own or control the customer, or the natural person(s) on whose behalf a transaction is being conducted. For legal entities, this often involves identifying individuals holding 25% or more of the shares or voting rights, or otherwise exercising control.

**Purpose and Intended Nature of Business Relationship**: Understand the reason for the customer seeking services from the VASP and the nature of transactions they intend to conduct.

**Ongoing Monitoring**: Continuously monitor the business relationship and transactions to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile, including (where necessary) the source of funds.

**Enhanced Due Diligence (EDD)**: Apply EDD measures for higher-risk customers, relationships, or transactions. This includes, but is not limited to:

Customers from high-risk jurisdictions identified by FATF or local authorities.

Complex or unusually large transactions.

Transactions with no apparent economic or lawful purpose.

Cross-border correspondent relationships for VASPs.

The "Travel Rule" (FATF Recommendation 16 for VASPs) requires VASPs to obtain, hold, and transmit required originator and beneficiary information for virtual asset transfers above a certain threshold.

**Source of Funds/Wealth**: For high-risk customers or transactions, VASPs may be required to obtain information on the source of funds or wealth involved.

**Reporting Obligation**: Any VASP employee or officer who knows, suspects, or has reasonable grounds to suspect that funds are the proceeds of criminal activity (including money laundering or terrorist financing) must report their suspicions to the FIU without delay.

**"No Tipping-Off"**: VASPs and their employees are prohibited from informing the customer or any third party that an STR has been filed or that information is being provided to the FIU.

**Internal Reporting**: VASPs must establish internal procedures for reporting suspicious activities to a designated Money Laundering Reporting Officer (MLRO) within the VASP, who is then responsible for filing the STR with the FIU.

**Customer Identification Data**: All records obtained through CDD procedures, including copies of identification documents, verification data, and beneficial ownership information.

**Transaction Data**: Records of all transactions, including amounts, types of virtual assets, dates, and parties involved.

**Business Correspondence**: Records of all correspondence with customers, particularly those related to unusual or suspicious activity.

**Retention Period**: Records must generally be kept for a minimum of **five (5) years** after the business relationship has ended or after the date of the transaction.

**Risk-Based Approach**: VASPs must adopt a risk-based approach to AML/CFT, meaning they should assess the money laundering and terrorist financing risks associated with their customers, products, services, and geographical areas, and apply measures proportionate to these risks.

**Internal Controls**: Establish robust internal controls, policies, and procedures to prevent money laundering and terrorist financing.

**Training**: Provide regular and ongoing AML/CFT training to all relevant employees, ensuring they understand their obligations and can identify suspicious activities.

**Compliance Officer**: Appoint a designated Money Laundering Reporting Officer (MLRO) and potentially a compliance officer responsible for overseeing AML/CFT compliance.

**Virtual Assets:** The most probable classification for stablecoins in Dominica is as "virtual assets" under the **Virtual Asset Business Act, 2020**. This act defines a "virtual asset" as "a digital representation of value that can be digitally traded or transferred, and can be 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 laws."

**Implication:** Depending on how a specific stablecoin is structured (e.g., if it pegs to fiat currency but isn't a direct digital representation issued by a central bank), it could fall under this definition.

**Virtual Asset Business Act, 2020:** [Specific URL for Dominica's legislation is often difficult to find directly for smaller nations without a centralized legislative database accessible via stable public URLs. However, the Act exists and is administered by the FSU.]

**E-money/Payment Tokens:** If a stablecoin functions primarily as a medium of exchange and is widely accepted for payments, it *could* be considered analogous to e-money or a payment token. However, Dominica lacks specific private e-money regulations that would formally classify or govern such instruments from non-bank issuers. The ECCB issues the official digital currency (DXCD), which is e-money.

**Securities:** If a stablecoin's design confers rights akin to traditional securities (e.g., equity, debt, profit-sharing, or an expectation of profit from the efforts of others), it could potentially be classified as a security under the **Securities Act [Cap. 74:03]**. This would bring it under the purview of the Financial Services Unit (FSU).

**Securities Act [Cap. 74:03]:** [Again, direct public URL for specific consolidated Acts are often elusive for smaller jurisdictions. The Act would be part of Dominica's national laws.]

**No specific stablecoin reserve requirements:** There are no laws in Dominica explicitly mandating reserve requirements for private stablecoin issuers.

If a stablecoin issuer were deemed a Virtual Asset Service Provider (VASP) under the Virtual Asset Business Act, 2020, they would be subject to general financial soundness requirements, capital adequacy, and internal controls, but not specific reserve ratios for the stablecoin itself.

If, by some stretch, a stablecoin was deemed to be an unofficial "currency" or "e-money" competing with the Eastern Caribbean Dollar, the ECCB could intervene based on its mandate for monetary stability under the **Eastern Caribbean Central Bank Agreement Act**.

**No stablecoin-specific licensing:** Dominica does not have a license category exclusively for stablecoin issuers.

**Virtual Asset Service Provider (VASP) Licensing:** However, if an entity issues or facilitates the exchange, transfer, custody, or any other activity related to a stablecoin that falls under the definition of a "virtual asset business," then it would require licensing as a VASP under the **Virtual Asset Business Act, 2020**.

**Regulator:** The **Financial Services Unit (FSU) Dominica** is the supervisory authority responsible for licensing and regulating VASPs.

**Activities that would require a VASP license include (but are not limited to):**

Exchange between virtual assets and fiat currencies.

Exchange between one or more forms of virtual assets.

Custody or administration of virtual assets or instruments enabling control over virtual assets.

Participation in and provision of financial services related to an issuer's offer and/or sale of a virtual asset.

**No specific stablecoin redemption rights legislation:** There are no dedicated laws in Dominica guaranteeing redemption rights for stablecoin holders.

**Contract Law:** Redemption rights would primarily be governed by the terms and conditions agreed upon between the stablecoin issuer and the holder, under general contract law. Any failure to uphold these terms could lead to civil action.

**Consumer Protection:** If the stablecoin issuer is licensed as a VASP, the FSU would have general oversight regarding fair practices, which *might* implicitly cover aspects of redemption, but it's not a direct, guaranteed right under current law.

**No specific rules:** There are no specific regulatory provisions or rules in Dominica addressing algorithmic stablecoins. Given the inherent complexities and historical volatility of such designs, they would likely face significant scrutiny under existing VASP licensing processes due to potential risks to financial stability, consumer protection, and AML/CFT concerns. They would likely be viewed with extreme caution.

**Eastern Caribbean Central Bank (ECCB):** The ECCB is the monetary authority for the eight-member Eastern Caribbean Currency Union (ECCU), which includes Dominica. The ECCB has been a pioneer in launching a Central Bank Digital Currency (CBDC).

**DXCD (Digital Eastern Caribbean Dollar):** The ECCB officially launched its CBDC, the DXCD, for public use in 2021. The DXCD is the legal tender digital form of the Eastern Caribbean Dollar.

**Competition and Monetary Sovereignty:** The ECCB has a clear mandate to maintain monetary and financial stability. Private stablecoins, especially those pegged to foreign currencies, could be seen as competing with the DXCD and potentially undermining the ECCB's monetary sovereignty and control over the domestic money supply.

**Official Stance:** While the ECCB has expressed a generally open approach to innovation, it also emphasizes the need for robust regulation for private digital assets to mitigate risks. Their focus is on promoting the official DXCD. It is highly unlikely they would officially endorse or facilitate private stablecoins that could destabilize the monetary system.

**Legal Framework:** The **Eastern Caribbean Central Bank Agreement Act** forms the basis of the ECCB's authority, including its ability to issue currency and regulate the financial system. Any private stablecoin activity that encroaches upon the ECCB's mandate could face scrutiny.

**URL (ECCB Agreement Act):** https://www.eccb-centralbank.org/images/pdfs/eccb_agreement_act.pdf

**Virtual Assets Business Act, 2020:** While a direct government gazette URL is often difficult to find for small island nations without extensive online legislative databases, the Act is widely referenced by the Financial Services Unit (FSU) and international bodies. The FSU is the regulatory authority for VASPs in Dominica.

Financial Services Unit (FSU) Dominica: https://fsu.gov.dm/ (You would typically look for legislation or guidance documents here.)

**FATF Travel Rule Thresholds (General Guidance Dominica is expected to follow):**

**For VASP-to-VASP transfers:** All transfers of virtual assets, regardless of amount, should include the required originator and beneficiary information collected by the respective VASPs.

**For transmission of information between VASPs:**

For transactions **equal to or above USD/EUR 1,000 (or its equivalent in virtual assets)**, VASPs are required to obtain and transmit comprehensive originator and beneficiary information.

For transactions **below USD/EUR 1,000**, VASPs are still required to collect the originator and beneficiary information, but the immediate transmission of full details to the beneficiary VASP may follow a risk-based approach, though the global trend is towards transmitting full information for all VASP-to-VASP transfers where possible.

**For transfers to/from unhosted wallets:** VASPs are expected to adopt a risk-based approach to determine when to collect originator/beneficiary information for transfers to/from unhosted wallets, particularly above the USD/EUR 1,000 threshold.

Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets (custody).

Any other activity specified by regulation as a virtual asset business.

Conduct customer due diligence (CDD) and enhanced due diligence (EDD) where necessary.

Monitor transactions for suspicious activity.

Maintain records for a specified period (typically 5-7 years).

Report suspicious transactions to the Financial Intelligence Unit (FIU).

Have systems and controls in place to identify the originator and beneficiary of virtual asset transfers and transmit that information to the receiving VASP (i.e., comply with the Travel Rule).

**Fines:** Substantial monetary penalties for both the VASP entity and responsible individuals within the VASP (e.g., directors, officers).

**Imprisonment:** For serious offenses, individuals may face terms of imprisonment.

**License Revocation or Suspension:** The FSU has the power to suspend or revoke a VASP's license to operate.

**Reputational Damage:** Public sanctions or enforcement actions can severely damage a VASP's reputation.

**Cease and Desist Orders:** The FSU can issue orders requiring non-compliant activities to stop.

**Virtual Asset Business Act, 2020 (VABA):** This is the foundational law for regulating Virtual Asset Service Providers (VASPs) in Dominica. It requires VASPs to be licensed by the Financial Services Unit (FSU) and sets out their obligations, including AML/CFT compliance.

**Money Laundering (Prevention) Act, 2017 (as amended):** This Act provides the primary framework for anti-money laundering (AML) obligations for all financial institutions and designated non-financial businesses and professions (DNFBPs), which now includes VASPs. It mandates customer due diligence (CDD), record-keeping, and suspicious transaction reporting.

**Anti-Terrorism Act, 2003 (as amended):** This Act criminalizes terrorism and its financing, and provides for the implementation of UN Security Council Resolutions related to targeted financial sanctions.

**Proceeds of Crime Act, 2017:** Deals with the confiscation of assets derived from criminal activities.

**Financial Intelligence Unit (FIU) Dominica:** This is the central national authority responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other financial information related to suspected money laundering, terrorist financing, and proliferation financing. It also provides guidance to reporting entities.

**Obligation for VASPs:** Under the Anti-Terrorism Act and the Money Laundering (Prevention) Act, VASPs in Dominica are legally required to:

**Screen against UN Sanctions Lists:** Regularly screen their customers, beneficial owners, and transaction parties against the consolidated UN Security Council Sanctions List (which includes ISIL (Da'esh) & Al-Qaida Sanctions List, Taliban Sanctions List, DPRK Sanctions List, Iran Sanctions List, etc.).

**Freeze Assets:** Immediately freeze any virtual assets or other funds belonging to or controlled by designated persons or entities identified on UN sanctions lists, without prior notice.

**Report Freezes:** Report any frozen assets and attempts to transact with sanctioned parties to the FIU Dominica without delay.

**Prohibit Dealings:** Refrain from making any funds or virtual assets available, directly or indirectly, to or for the benefit of designated persons or entities.

**Anti-Terrorism Act, 2003 (as amended):** Sections 13 and 14 deal with the prohibition of financing terrorism and the duty to report.

**UN Security Council Consolidated Sanctions List:** https://www.un.org/securitycouncil/sanctions/information

**Indirect Application:** Any VASP in Dominica that:

Deals with U.S. dollar-denominated virtual assets or fiat.

Engages with U.S. persons (citizens, residents, entities).

Uses U.S. financial systems or payment processors.

Conducts transactions that clear through the U.S. banking system.

Utilizes U.S.-based technology or infrastructure.

**Best Practice/Risk Mitigation:** Even for transactions not directly involving the U.S. nexus, most international VASPs in Dominica adopt OFAC compliance as a best practice to maintain correspondent banking relationships, avoid de-risking by global financial institutions, and preserve their international reputation.

**Obligation for VASPs:** VASPs should screen customers, beneficial owners, and transaction parties against the OFAC Specially Designated Nationals (SDN) and Blocked Persons List, and other relevant OFAC sanctions lists.

**OFAC Sanctions Programs and Information:** https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information

**Indirect Application:** VASPs dealing with EU persons, entities, or utilizing EU financial infrastructure may fall under the purview of EU sanctions regulations.

**Best Practice/Risk Mitigation:** Compliance with EU sanctions is also a common international best practice for VASPs seeking to operate globally and maintain strong relationships with EU-based financial institutions.

**Obligation for VASPs:** VASPs should screen against the EU Consolidated List of persons, groups, and entities subject to EU financial sanctions.

**EU Financial Sanctions Database:** https://data.europa.eu/euodp/en/data/dataset/consolidated-list-of-persons-groups-and-entities-subject-to-eu-financial-sanctions

**Mandatory Screening:** As part of their CDD procedures and risk-based approach, VASPs must screen all customers (both natural and legal persons), beneficial owners, and, where feasible, counterparties to transactions against relevant sanctions lists.

**Risk-Based Approach:** The intensity and frequency of screening should be commensurate with the VASP's risk assessment of the customer and the transaction. Higher-risk customers or transactions warrant more rigorous and frequent screening.

**UN Sanctions Lists (Mandatory):** This is a direct legal obligation.

**OFAC SDN List (Highly Recommended/Indirectly Mandatory):** Essential for international operations, USD transactions, and avoiding U.S. secondary sanctions.

**EU Consolidated List (Highly Recommended):** Important for interactions with EU jurisdictions and entities.

**Other Relevant Lists:** Depending on the VASP's global footprint, screening against other national sanctions lists (e.g., UK, Canada) may be advisable.

**Ongoing Monitoring:** Screening is not a one-time event. VASPs must implement ongoing monitoring processes to identify changes in status (e.g., a customer being newly added to a sanctions list) and rescreen customers periodically or upon triggers.

**Virtual Asset Business Act, 2020:** Section 18 outlines general AML/CFT requirements for licensed VASPs.

**Sanctioned Jurisdictions:** Transactions originating from or destined for jurisdictions subject to comprehensive UN, OFAC, or EU embargoes (e.g., Cuba, Iran, North Korea, Syria, certain regions in Ukraine/Russia) are inherently high-risk. While not a blanket ban from Dominica, VASPs must exercise enhanced due diligence (EDD) and may be legally prohibited from processing transactions involving sanctioned individuals or entities within those jurisdictions, or the jurisdictions themselves if under a full embargo.

**High-Risk Jurisdictions:** The Financial Action Task Force (FATF) issues statements identifying jurisdictions with strategic AML/CFT deficiencies ("grey list" and "black list"). While not "sanctioned," transactions involving these countries trigger EDD requirements for VASPs in Dominica.

**FATF Recommendation 15 (Virtual Assets):** Dominica, as a member of CFATF (a FATF-style regional body), is expected to implement FATF recommendations, which include a risk-based approach to virtual assets. This means transactions involving higher-risk geographic areas will require stricter controls.

**Under the Virtual Asset Business Act, 2020:**

**General Offences:** Section 31(1) states that a person who commits an offence under the Act for which no specific penalty is provided is liable on summary conviction to a fine not exceeding **one hundred thousand dollars (XCD 100,000)** or to imprisonment for a term not exceeding **ten years**, or to both.

**Failure to Comply with Conditions:** Section 32 provides for penalties, including fines and imprisonment, for failing to comply with licensing conditions or other requirements of the Act.

**Licence Revocation:** Non-compliance can lead to the suspension or revocation of a VASP's license by the FSU.

**Under the Money Laundering (Prevention) Act, 2017 (as amended):**

**Failure to Report Suspicion (STRs):** Section 35 states that a person who fails to comply with the duty to report suspicion is liable on summary conviction to a fine not exceeding **five hundred thousand dollars (XCD 500,000)** or to imprisonment for a term not exceeding **five years**, or to both.

**Tipping-Off:** Section 36 makes "tipping-off" an offense, with similar penalties.

**Concealment/Possession of Proceeds of Crime:** Section 34 covers various money laundering offenses with penalties including significant fines and imprisonment.

**Under the Anti-Terrorism Act, 2003 (as amended):**

**Financing of Terrorism:** Section 13 imposes severe penalties, including lengthy imprisonment terms (e.g., up to 30 years) and substantial fines, for individuals involved in the financing of terrorism.

**Failure to Report:** Section 14 mandates reporting of information related to terrorist acts or financing, with penalties for non-compliance.

**Reputational Damage and Loss of Banking Relationships:** Beyond legal penalties, non-compliance can lead to significant reputational damage, loss of trust, and the inability to secure or maintain banking services, effectively forcing a VASP out of business.

**Virtual Asset Business Act, 2020:** [Specific legal acts for Dominica are sometimes difficult to find publicly online directly from government sources. They are typically available through the Attorney General's Chambers or the Parliament Library. However, legislative summaries and related guidance are often on the FIU's site or Caribbean legal databases.]

**Anti-Terrorism Act, 2003 (as amended):** https://www.fiu.gov.dm/download/anti-terrorism-act-no-10-of-2003/ (and subsequent amendments).

The **FIU Dominica** is the national body responsible for overseeing AML/CFT compliance, including sanctions. While they may issue guidance or consolidate relevant international lists for local reporting entities, they do not generate their own unique sanctions list for crypto.

Any country-specific "sanctions" would typically arise from Dominica's implementation of broader international regimes, primarily those of the UN.

**Regulator Name:** **Financial Services Unit (FSU)**

**Role:** The FSU is Dominica's primary regulator for non-bank financial institutions. It is responsible for licensing, supervising, and regulating financial services entities, including Virtual Asset Service Providers (VASPs). Dominica has enacted the **Virtual Asset Business Act, 2020**, which brings VASPs under the FSU's oversight for licensing and AML/CFT compliance.

**Enforcement Focus (General):** While they would be the primary body for enforcement, public records of specific crypto enforcement actions (fines, cease and desist orders against named entities) are not readily available. Their work primarily involves ensuring compliance with licensing requirements and AML/CFT obligations.

Financial Services Unit, Dominica: https://fsu.gov.dm/

Virtual Asset Business Act, 2020 (Dominica) - available via legal resources or local government gazettes.

**Regulator Name:** **Financial Intelligence Unit (FIU) Dominica**

**Role:** The FIU is responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) related to money laundering and terrorist financing. This includes activities involving virtual assets. They cooperate with law enforcement and regulatory bodies.

**Enforcement Focus (General):** The FIU investigates financial crimes, but their actions typically lead to broader criminal investigations or shared intelligence, rather than public "enforcement actions" with fines detailed by the FSU or a court for specific crypto violations against a named entity.

**Regulator Name:** **Eastern Caribbean Central Bank (ECCB)**

**Role:** The ECCB is the monetary authority for the eight-member OECS, including Dominica. While not a direct regulator of individual VASPs, the ECCB plays a crucial role in maintaining financial stability and often issues warnings or guidance regarding unregulated financial activities, including certain aspects of cryptocurrencies. They have also led the DCash pilot project, a digital version of the Eastern Caribbean dollar.

**Enforcement Focus (General):** The ECCB primarily focuses on systemic risks and overall financial stability. Their actions usually involve policy statements, advisories, or collaboration with national regulators. They are less likely to issue specific enforcement actions against private crypto entities in individual member states.

Eastern Caribbean Central Bank: https://www.eccb-centralbank.org/

**No publicly documented significant cryptocurrency enforcement actions** meeting all the specified criteria (regulator name, entity targeted, violation type, penalty amount, date, and outcome) could be found for Dominica in the last three years.

Dominica has established the **Virtual Asset Business Act, 2020**, indicating a commitment to regulate VASPs under the FSU's purview and comply with international AML/CFT standards. This framework is relatively new, and the focus seems to be on implementation and compliance rather than frequent public enforcement reports.

It's possible that private enforcement actions, warnings, or regulatory guidance have occurred without public disclosure, or that enforcement actions are part of broader AML/CFT investigations that are not specifically categorized or publicized as "cryptocurrency enforcement actions" with detailed fines.