Centralized exchange in 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.

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.

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

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

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.

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.

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.

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.

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.

Not Adopted (for VASPs): Suriname's AML/CFT framework, as detailed in its 2019 Mutual Evaluation Report and 2021 Follow-Up Report, does not yet define or regulate Virtual Assets or Virtual Asset Service Providers. Without this fundamental recognition and regulatory framework, the specific requirements of the FATF Travel Rule (Recommendation 16, as applied to VASPs under Recommendation 15) cannot be effectively adopted or implemented.

The CFATF MER for Suriname (2019) noted that the country had not conducted a risk assessment related to VAs and VASPs, nor had it put in place any legislation or regulation to define, license, register, or supervise them for AML/CFT purposes.

The 2nd Enhanced Follow-Up Report & Technical Compliance Re-Rating (2021) continued to reflect this deficiency, stating that Recommendation 15 (New Technologies) remained "Non-Compliant" due to the absence of a legal framework for VAs and VASPs.

Effective Date: There is no effective date for the Travel Rule as it has not been adopted for VASPs.

Threshold Amounts: No specific threshold amounts for the Travel Rule apply to VASPs in Suriname.

Which VASPs are Covered: VASPs are not explicitly covered by AML/CFT obligations in Suriname, as there is no legal framework defining or regulating them.

Technical Implementation Requirements: There are no prescribed technical implementation requirements for the Travel Rule for VASPs.

Penalties for Non-Compliance: Penalties specifically for Travel Rule non-compliance by VASPs do not exist, as VASPs are not currently subject to this regulation. While Suriname has general AML/CFT penalties for regulated financial institutions and DNFBPs, these would not apply to unregistered/unregulated VASPs concerning the Travel Rule.

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.