Custodial wallet / SaaS in 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.

Custody Providers: No specific custody license for virtual assets.

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.

No specific capital requirements for virtual asset businesses.

General IBC registration has no minimum capital requirement.

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

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.

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

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.

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.

Identification and Verification of Customers:

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.

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:

Politically Exposed Persons (PEPs).

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

Complex or unusually large transactions.

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.

Financial Services Unit (FSU):

Financial Intelligence Unit (FIU):

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

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.

Regulator Name: Financial Services Unit (FSU)