Suriname

**Centrale Bank van Suriname (CBS)**: The central bank is the primary financial regulator in Suriname and has issued official statements regarding cryptocurrencies.

**Neither a specific licensing nor a specific registration regime for VASPs exists.**

The CBS has maintained a cautious stance, primarily focusing on warning the public about the risks associated with virtual assets (volatility, scams, lack of consumer protection, money laundering risks).

There are no specific licenses or permits issued by the CBS or any other Surinamese authority explicitly for operating a crypto exchange, providing crypto custody, or processing crypto payments as distinct from traditional financial services.

**No specific crypto-related licenses are required** because the legal framework for virtual assets is currently absent.

**However, this does not imply a "free pass."** If an entity's operations begin to resemble traditional financial services (e.g., taking deposits, issuing financial instruments, providing lending services that involve fiat currency or carry financial risk) it *could* potentially fall under existing financial services laws and require traditional banking, money transfer, or investment licenses from the CBS. This would be determined on a case-by-case basis by the CBS.

**AML/KYC (Anti-Money Laundering/Know Your Customer):**

**Mandatory.** Even without a specific crypto law, Suriname, as a member of the Caribbean Financial Action Task Force (CFATF) and generally following FATF Recommendations, has robust AML/CFT legislation.

Any entity dealing with significant financial transactions, including those involving virtual assets that can be converted to fiat or used for value transfer, would be expected to comply with Suriname's AML/CFT laws.

**Relevant Legislation:** Suriname's primary AML/CFT legislation includes the **"Wet identificatie bij dienstverlening ter voorkoming van witwassen en financiering van terrorisme" (Act on Identification when Providing Services to Prevent Money Laundering and Terrorism Financing)** and related decrees. This law requires designated institutions (banks, money transmitters, casinos, trust companies, etc.) to:

Conduct customer due diligence (CDD/KYC).

Monitor transactions for suspicious activity.

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

While VASPs are not explicitly listed in older versions of this law, the international trend is for them to be treated as financial institutions or designated non-financial businesses and professions (DNFBPs) for AML purposes. Any VASP operating in Suriname would be under pressure to implement strong AML/CFT controls.

Not applicable for a non-existent crypto license.

If an operation were deemed to fall under traditional financial licensing, then specific capital requirements would apply based on the type of traditional license (e.g., banking license, money transmitter license).

Not a specific requirement for a crypto license, as none exists.

However, for AML/CFT compliance and general business operations targeting Surinamese residents, having a registered local entity and a physical presence (or at least a registered agent) would be prudent and often necessary for opening bank accounts and complying with local tax laws.

**There is no specific application process** for a crypto license as no such license exists.

**Centrale Bank van Suriname (CBS) Official Website:**

*Significance:* This is the main financial regulator. While specific crypto laws aren't here, any official statements or future regulations would originate from or be published by the CBS.

**CBS Press Release/Advisory on Cryptocurrencies (Example - 2018):**

*Significance:* These statements indicate the official stance of the regulator, emphasizing risks and the current lack of regulation or legal tender status.

**Suriname's Financial Intelligence Unit (FIU) Website:**

*Significance:* The FIU is responsible for receiving and analyzing suspicious transaction reports (STRs) related to money laundering and terrorism financing. Any VASP operating in Suriname, even without a specific license, would likely fall under the purview of FIU reporting obligations if their activities constitute financial services or designated non-financial business activities that carry AML risk.

Suriname's primary AML/CFT law is the **"Wet identificatie bij dienstverlening ter voorkoming van witwassen en financiering van terrorisme" (Act on Identification when Providing Services to Prevent Money Laundering and Terrorism Financing)**.

*Note on URL:* Direct, stable, publicly accessible English translations or original Dutch versions of national laws from smaller jurisdictions are often difficult to link directly. They are typically published in the Official Gazette (Staatsblad van de Republiek Suriname) and may not have a continuously available direct URL on government websites. However, its existence and implications for financial institutions are well-established.

**Wet Toezicht Bank- en Kredietwezen 1993 (Banking and Credit Supervision Act 1993):** This is the foundational act for financial institutions, though it doesn't explicitly mention cryptocurrencies. However, if an entity issuing or dealing with tokens is deemed to be performing banking or credit-related activities, this act would apply.

**Wet ter voorkoming en bestrijding van witwassen en financiering van terrorisme (WWFT) (Anti-Money Laundering and Combatting Financing of Terrorism Act):** This act is highly relevant for all entities dealing with virtual assets, requiring them to implement AML/CFT measures, regardless of whether the token is classified as a security.

**Investment Tokens (Security Tokens/STOs):** Tokens that explicitly represent a share in a company, debt, participation in profits, voting rights, or other traditional financial instruments. These are designed from inception to be securities.

**Initial Coin Offerings (ICOs) where tokens are sold with an expectation of profit:** If the token is marketed as an investment opportunity, and its value is expected to grow based on the efforts of the issuing team, it would likely be deemed a security. This includes many early-stage project tokens.

**Tokens promising dividends, revenue share, or interest payments:** Any token that offers a passive income stream to holders, similar to a bond or stock dividend, would almost certainly be considered a security.

**Tokens that grant rights similar to equity or debt:** Even if not explicitly called a "share," if the token provides economic rights equivalent to traditional shares or debt instruments, it would fall under securities regulations.

**Pure Utility Tokens:** If the token's primary purpose is to grant access to a specific product or service within an ecosystem, and it is primarily acquired for its utility rather than investment, it is less likely to be a security. However, if the utility is not yet functional and the token is speculative, it could still be deemed a security.

**Pure Payment Tokens (e.g., Bitcoin, stablecoins used solely for payments):** Cryptocurrencies functioning solely as a medium of exchange or a store of value, without offering investment rights in a common enterprise. The CBvS has, however, stated that cryptocurrencies are **not legal tender** in Suriname.

**Prospectus Requirements:** Issuers might need to prepare and file a prospectus or offering document with the CBvS, providing full disclosure about the project, the token, risks, and financial information, similar to a traditional public offering of securities.

**Licensing:** The issuer or any intermediary involved in the offering (e.g., an underwriter or broker-dealer) might need to be licensed by the CBvS as a financial institution or investment firm.

**AML/CFT Compliance:** All token issuers and platforms dealing with virtual assets are expected to comply with the WWFT, including implementing Know Your Customer (KYC) procedures and reporting suspicious transactions.

**Exchange Licensing:** Any platform facilitating the trading of such security tokens would need to be licensed by the CBvS as a securities exchange or a trading facility.

**Market Conduct Rules:** Rules against market manipulation, insider trading, and other illicit market practices would apply.

**Reporting Requirements:** Trades might need to be reported to the CBvS.

**Warnings about Risks:** The CBvS has repeatedly warned the public about the high risks associated with investing in cryptocurrencies, citing their volatility, lack of underlying value, and susceptibility to cybercrime and fraud.

**No Legal Tender Status:** It has clarified that cryptocurrencies are not legal tender in Suriname and are not regulated by the CBvS. This implicitly discourages their use in the formal financial system.

**Emphasis on AML/CFT:** While not specifically about securities, the CBvS expects financial institutions and other relevant entities to comply with AML/CFT obligations when dealing with virtual assets, to combat illicit financing.

**Warnings against Unlicensed Activities:** While not directly crypto-specific, the CBvS has historically acted against entities conducting financial services without proper licenses. If a crypto offering were deemed to fall under existing securities or financial services laws, an unlicensed operation would be subject to enforcement action.

**Centrale Bank van Suriname (CBvS) Official Website:** https://www.cbvs.sr/

You would typically look under sections like "Nieuws & Publicaties" (News & Publications) or "Wet- en Regelgeving" (Laws & Regulations) for relevant statements or acts.

Specific legal acts like the "Wet Toezicht Bank- en Kredietwezen 1993" or "Wet ter voorkoming en bestrijding van witwassen en financiering van terrorisme" would be administered by or referenced by the CBvS, though direct public access to full, updated texts might require legal databases or government gazettes within Suriname.

**None specifically for crypto custody.** There is no specific licensing regime in Suriname for companies providing cryptocurrency or digital asset custody services.

Suriname's existing financial services licensing laws (e.g., for banks, money transfer businesses) do not explicitly cover or define virtual asset custody as a regulated activity.

**Regulatory Reference (Indirect):** The FATF Mutual Evaluation Report for Suriname (published in 2020 and subsequent follow-up reports) indicates that Recommendation 15 (which addresses Virtual Assets and Virtual Asset Service Providers) has significant deficiencies. Suriname has been rated as "Non-Compliant" or "Partially Compliant" with this recommendation, specifically noting that there is no legal or regulatory framework for the licensing, registration, or supervision of VASPs for AML/CFT purposes.

**FATF Mutual Evaluation Report of Suriname (2020):** https://www.fatf-gafi.org/content/fatf-gafi/en/countries-regions/s-t/suriname/documents/mer-suriname-2020.html (Look specifically at ratings for R.15 and findings related to VASPs).

**No specific rules.** Given the absence of a dedicated regulatory framework for crypto custodians, there are no explicit mandates or guidelines requiring the segregation of client digital assets from the custodian's own assets.

**None.** There are no specific insurance or bonding requirements for entities providing crypto custody services in Suriname.

**None.** No specific regulations or mandates exist regarding the use of cold storage (offline storage) for digital assets held in custody.

**No specific definition.** Suriname's existing laws do not define what constitutes a "qualified custodian" in the context of digital assets.

As of the latest available public information, there is **no specific pending legislation** in Suriname focused on regulating cryptocurrency or digital asset custody.

However, as a member of the Caribbean Financial Action Group (CFATF) and under the oversight of the FATF, Suriname is under pressure to improve its AML/CFT framework, which *could* eventually lead to the regulation of VASPs. Any future legislation would likely first address basic AML/CFT registration/licensing before moving to specific operational requirements like custody rules.

**Centrale Bank van Suriname (CBvS) Official Website:** While not specific to custody legislation, this is the primary source for any official announcements or regulations regarding financial services in Suriname. You would need to monitor their news and publications sections.

https://www.cbvs.sr/ (Website primarily in Dutch)

**Obligation:** As a UN member state, Suriname is legally bound to implement sanctions resolutions passed by the UN Security Council. These resolutions target individuals, entities, and countries involved in terrorism, proliferation of weapons of mass destruction, and other threats to international peace and security.

**Implementation in Suriname:** The Government of Suriname, through its financial regulators (primarily the Centrale Bank van Suriname - CBvS) and its Financial Intelligence Unit (FIU-S), is responsible for circulating UN sanctions lists (e.g., the UN Security Council Consolidated List) and ensuring financial institutions (which would include VASPs if regulated) comply.

**VASP Requirements:** VASPs operating in or from Suriname, or dealing with Surinamese customers, must screen all their customers (KYC/CDD) and transactions against the UN sanctions lists. If a match is found, assets must be frozen, and a report made to the FIU-S.

**UN Security Council Resolutions:** Accessible via the UN Digital Library: https://digitallibrary.un.org/

**UN Security Council Consolidated List:** https://www.un.org/securitycouncil/sanctions/un-sc-consolidated-list

**Extraterritorial Reach:** The U.S. Office of Foreign Assets Control (OFAC) sanctions primarily apply to "U.S. persons" (U.S. citizens, permanent residents, entities organized under U.S. law, and persons within the U.S.). However, OFAC sanctions can have significant extraterritorial effects, especially through secondary sanctions and when transactions involve the U.S. financial system or U.S.-origin technology.

If a VASP operating in Suriname (or its parent company) is a U.S. person, it must comply fully with OFAC regulations.

If a VASP in Suriname transacts with U.S. persons or uses U.S.-based virtual asset exchanges, custodians, or other service providers, those U.S. entities will require OFAC compliance, indirectly impacting the Surinamese VASP.

Engaging in transactions with OFAC-sanctioned individuals, entities, or jurisdictions (e.g., Iran, North Korea, Cuba, Syria, specific regions of Ukraine) via cryptocurrency can expose non-U.S. VASPs to significant risk of U.S. enforcement action, including being added to the SDN list.

**VASP Requirements:** VASPs must screen customers and transactions against OFAC's Specially Designated Nationals and Blocked Persons (SDN) List and other sanctions lists. They should also be aware of OFAC's guidance specifically addressing virtual currency.

**OFAC Virtual Currency Guidance:** Search for "OFAC Guidance on Virtual Currency" on the Treasury website (e.g., the "Sanctions Compliance Guidance for the Virtual Currency Industry"): https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/2311

**Applicability:** EU sanctions apply to all EU persons, entities, and anyone operating within the EU's jurisdiction. While Suriname is not an EU member, VASPs in Suriname that have a nexus with the EU (e.g., European ownership, serving EU customers, using EU-based service providers, or transacting with EU-sanctioned individuals/entities) could fall under the scope of EU sanctions.

**VASP Requirements:** Similar to OFAC, VASPs with an EU nexus must screen against EU sanctions lists, freeze assets, and report to relevant authorities if matches are found.

The CBvS is the central bank and primary financial regulator in Suriname. While it has issued warnings about the risks of cryptocurrencies, comprehensive specific regulations for VASPs are still under development or not yet fully enacted. However, any financial activity, including those involving virtual assets, is expected to adhere to general AML/CFT principles.

The FIU-S is the national center for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other information related to money laundering and terrorist financing.

**Role in Sanctions:** The FIU-S would be the primary recipient of reports regarding suspected sanctions violations involving virtual assets, once a clear reporting mechanism for VASPs is established. It also disseminates UN sanctions lists domestically.

Suriname has laws in place to combat money laundering and terrorist financing, such as the **Wet Melding Ongebruikelijke Transacties (WMOT)** (Reporting Unusual Transactions Act) and related regulations. These laws implement FATF Recommendations and UN Security Council Resolutions.

**Application to Crypto:** Even without specific crypto regulations, financial institutions (and potentially VASPs under a broader interpretation or future specific designation) are expected to report suspicious transactions to the FIU-S. This would include transactions suspected of being linked to sanctioned entities or jurisdictions.

**FATF Recommendations:** Suriname, as a jurisdiction subject to FATF assessments, is expected to implement FATF Recommendation 15 (New Technologies), which requires countries to regulate and supervise VASPs for AML/CFT purposes, including sanctions compliance.

**FATF Guidance for a Risk-Based Approach to Virtual Assets and VASPs:** https://www.fatf-gafi.org/publications/fatfrecommendations/guidance-rba-virtual-assets-2023.html

**Customer Due Diligence (CDD) / Know Your Customer (KYC):** Identify and verify the identity of all customers, including beneficial owners.

**Sanctions Screening:** Screen all customers and counterparties (where identifiable), as well as ongoing transactions, against:

**UN Sanctions Lists:** The Consolidated List (terrorists, proliferation, specific regimes).

**OFAC SDN List and other relevant OFAC lists:** For any U.S. nexus or to mitigate secondary sanctions risk.

**EU Sanctions Lists:** For any EU nexus.

**Adverse Media Screening:** Check for any news or reports linking customers to criminal activity or sanctions evasion.

**Blockchain Analytics:** Utilize tools to identify links to known illicit addresses, sanctioned wallets, or high-risk jurisdictions.

**Ongoing Monitoring:** Continuously monitor customer activity and re-screen against updated sanctions lists.

**Crimea, Donetsk, Luhansk, Kherson, Zaporizhzhia regions of Ukraine (under Russian control)**

**Russia** (extensive sanctions by US, EU, UK, etc., though UN sanctions are less broad)

Other jurisdictions under specific UN, OFAC, or EU sanctions programs (e.g., certain individuals/entities in Belarus, Venezuela, Myanmar, etc.).

**Financial Penalties:** Substantial fines for individuals and legal entities.

**Imprisonment:** Criminal charges leading to significant prison sentences for individuals involved.

**Asset Forfeiture:** Seizure and forfeiture of assets involved in or derived from illicit activities, including virtual assets.

**Reputational Damage:** Significant harm to the reputation of the VASP and individuals involved.

**Loss of License/Operating Ability:** If a regulatory framework for VASPs is established, non-compliance would likely lead to license revocation.

**International Penalties:** If OFAC or EU sanctions are violated, U.S. or EU authorities can impose their own substantial fines, designate the VASP or individuals on their sanctions lists, and block access to their financial systems.

**Developing Regulatory Framework:** Suriname is still in the early stages of developing a comprehensive regulatory framework for virtual assets and cryptocurrencies. The Centrale Bank van Suriname (CBvS) and the Financial Intelligence Unit (FIU) are the primary financial regulators, but their focus has largely been on issuing warnings, conducting risk assessments, and working towards future legislation, rather than active enforcement against specific entities with public penalties.

**Focus on Warnings and Risk Advisory:** The Centrale Bank van Suriname (CBvS) has, on multiple occasions, issued warnings to the public about the risks associated with investing in or using cryptocurrencies, emphasizing their volatile nature, lack of legal tender status, and potential for fraud and money laundering. These are advisories, not enforcement actions against specific entities.

**International Recommendations (FATF):** Suriname, like many countries, is subject to recommendations from the Financial Action Task Force (FATF) regarding Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) for virtual assets. While these reports assess a country's progress, they do not detail specific domestic enforcement actions against individual entities.

**Lack of Publicly Disclosed Cases:** Significant enforcement actions, especially those involving penalties and specific outcomes, are typically publicized by financial authorities to deter future violations. The absence of such public disclosures from the CBvS, the FIU, or major news outlets indicates that such actions have not occurred or have not been made public within the specified timeframe.

**Centrale Bank van Suriname (CBvS):** The central bank, responsible for monetary policy, financial stability, and supervision of financial institutions. It has issued warnings regarding cryptocurrencies.

**Financial Intelligence Unit (FIU) Suriname:** Responsible for receiving, analyzing, and disseminating suspicious transaction reports related to money laundering and terrorist financing. They would be involved in investigating crypto-related illicit financial activities.

**Centrale Bank van Suriname Official Statements:** The CBvS periodically issues press releases and statements regarding financial sector developments, including warnings about unregulated financial products like cryptocurrencies. Searching their official website (www.cbvs.sr) would show general advisories, but not enforcement actions.

*Example of a general warning (though pre-2021, reflects ongoing stance):*

**FATF Reports:** The FATF evaluates countries' AML/CFT frameworks, including for virtual assets. Suriname's evaluations discuss its legal framework development but not individual enforcement actions.