Crypto ATM / kiosk operator in Grenada
Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.
Crypto ATM is conditionally permitted in Grenada with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- Registration with the FIU as a VASP reporting entity under the Proceeds of Crime Act (gd.licensing.virtual-asset-businesses-are-designated)
- Licensing by GARFIN under the Virtual Asset Business Act (VABA) 2020 (gd.enforcement.virtual-asset-business-act-vaba)
- Implement Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk customers, including cash-in/cash-out customers (gd.aml.amlcft-program-vasps-must-implement; gd.licensing.customer-due-diligence-cdd-and)
- Risk-based approach to AML/CFT, including transaction monitoring for suspicious activity (gd.licensing.risk-based-approach-to-assessing-and; gd.licensing.monitoring-of-transactions-for-suspicious)
- Record-keeping of transactions and customer identification data (gd.licensing.record-keeping-of-transactions-and-customer)
- Suspicious Transaction Reporting (STR) to the FIU (gd.licensing.reporting-of-suspicious-transactions-strs)
- Appointment of a designated AML/CFT Compliance Officer (gd.licensing.appointment-of-a-designated-amlcft)
- Ongoing employee training (gd.licensing.ongoing-training-for-employees)
- Maintain risk assessment frameworks (gd.aml.risk-assessment-frameworks)
Key Restrictions
- Must be a company incorporated or established in Grenada (gd.licensing.an-applicant-must-be-a)
- Must have directors or senior officers ordinarily resident in Grenada, or alternative arrangements acceptable to GARFIN (gd.licensing.while-the-act-does-not)
- Must pass a fit and proper test (gd.licensing.fit-and-proper-test)
- Must maintain sufficient capital as prescribed by the FSA (exact minimum capital to be confirmed with FSA) (gd.licensing.the-act-mandates-that-a; gd.licensing.the-specific-minimum-capital-requirements)
- The operating model (crypto ATM/kiosk) falls under 'exchange between virtual assets and fiat currencies' — requires a VASP license covering fiat-crypto exchange (gd.licensing.exchange-between-virtual-assets-and; gd.licensing.this-covers-all-forms-of)
Key Risks
- Regulatory ambiguity: No explicit cash-transaction reporting threshold (CTR equivalent) has been published for crypto ATMs in Grenada — the risk of unannounced thresholds or retroactive enforcement
- KYC infrastructure risk: Crypto ATMs involve cash-in/cash-out, which is inherently high-risk; the VASP framework requires EDD for high-risk customers but does not specify minimum verification standards for anonymous cash transactions at kiosks
- Enforcement immaturity: No significant public enforcement actions have been reported — operators face uncertainty about how aggressively GARFIN and the FIU will enforce (gd.enforcement.such-actions-have-not-occurred)
- Capital requirement uncertainty: Minimum capital amounts are not specified in statute and must be obtained from the FSA — this creates licensing timeline risk
- No explicit insurance/bonding mandate for custodianship of client digital assets (gd.aml.no-explicit-mandate-grenadas-current)
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Grenada Financial Services Authority (FSA): The competent authority responsible for licensing, supervision, and enforcement of the Virtual Asset Business Act.
Grenada Financial Intelligence Unit (FIU): Responsible for anti-money laundering and combating the financing of terrorism (AML/CFT) supervision of virtual asset businesses.
Exchange between virtual assets and fiat currencies.
This covers all forms of virtual asset exchanges, whether fiat-to-crypto, crypto-to-fiat, or crypto-to-crypto.
The Act mandates that a licensee must, at all times, maintain sufficient capital to carry on its virtual asset business.
The specific minimum capital requirements are to be prescribed by the Authority (FSA) through regulations or directives. Applicants should consult the FSA directly or its published guidelines for the exact amounts, which may vary depending on the scope of activities.
Virtual asset businesses are designated as "reporting entities" under Grenada's Proceeds of Crime Act and other AML/CFT legislation.
Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures (Know Your Customer - KYC).
Risk-based approach to assessing and mitigating money laundering and terrorism financing risks.
Record-keeping of transactions and customer identification data.
Monitoring of transactions for suspicious activities.
Reporting of suspicious transactions (STRs) to the FIU.
Appointment of a designated AML/CFT Compliance Officer.
Ongoing training for employees.
An applicant must be a company incorporated or established in Grenada. This requires a legal entity registered within the jurisdiction.
While the Act does not explicitly mandate all directors or senior officers to be Grenadian residents, it does require that the applicant "has directors or senior officers that are ordinarily resident in Grenada or other arrangements in respect of directors or senior officers that the Authority considers appropriate." This indicates a strong preference for or requirement of local management or significant operational presence.
Fit and Proper Test:
Financial Intelligence Unit (FIU) Grenada: This is the primary authority responsible for supervising and enforcing AML/CFT compliance for VASPs.
AML/CFT Program: VASPs must implement a comprehensive AML/CFT program, including:
Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk customers.
Suspicious Transaction Reporting (STR) to the FIU.
Registration/Notification: VASPs are generally required to register with the FIU and/or notify the FIU of their operations, ensuring compliance with AML/CFT obligations. This is not a specific "license" but a requirement to operate legally under the AML/CFT regime.
Virtual Asset Business Act (VABA), 2020: This Act provides the framework for the regulation of virtual asset businesses in Grenada, requiring them to be licensed by GARFIN and comply with AML/CFT requirements.
Require Registration/Licensing: All entities operating as Virtual Asset Service Providers (VASPs) in Grenada are legally required to be licensed by GARFIN and comply with AML/CFT regulations enforced by both GARFIN and the FIU.
Grenada Authority for the Regulation of Financial Institutions (GARFIN): This is the primary regulatory body for non-bank financial institutions and financial services in Grenada. It would likely oversee the licensing and conduct of Virtual Asset Service Providers (VASPs).
Financial Intelligence Unit (FIU) of Grenada: The FIU is responsible for receiving, analyzing, and disseminating financial information concerning suspected proceeds of criminal activity and terrorist financing. They would be involved in AML/CFT compliance for virtual assets.
Such actions have not occurred at a level deemed "significant" for public reporting.
No explicit mandate: Grenada's current AML/CFT framework for VASPs does not explicitly require custodians to carry specific insurance or bonding to cover potential losses of client digital assets.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — crypto ATM/kiosk operators may operate in Grenada as licensed VASPs under the Virtual Asset Business Act 2020, but must incorporate locally, obtain a VASP license from GARFIN for fiat-crypto exchange, comply with full AML/CFT obligations (CDD/EDD, STRs, compliance officer), and maintain sufficient capital as prescribed by the FSA, with no specific CTR threshold or kiosk-specific regulation yet published.
Questions this verdict aims to answer
- What money-transmitter / kiosk-specific license is required?
- What cash-transaction reporting thresholds apply?
- What enhanced-KYC obligations attach to cash-in / cash-out?