Remote VASP serving residents 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.

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.

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.

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.

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).

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.

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.

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.

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.