Crypto ATM / kiosk operator in Suriname

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

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.

Maintain proper records.

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.

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.

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.

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.

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.

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.

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.