Suriname -- Licensing Requirements Regulatory Overview

**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.