TTSEC: Virtual asset laws now in effect

The TT Securities and Exchange Commission (TTSEC) is reminding market participants and the general public that the VA/VASP Act 2025 (Virtual Assets and Virtual Asset Service Providers Act) was enacted by Presidential assent on December 23, and is now in effect.

The Act establishes a regulatory framework governing the conduct of virtual asset activities as a business in or from within TT.

Under the Act, the conduct of virtual asset activities as a business or on behalf of another person is temporarily prohibited until December 31, except where such activities are authorised by the TTSEC under the Regulatory Sandbox framework established by the Act.

This transitional regulatory measure seeks to:
• Prevent illegal scams, money laundering, and terrorist financing associated with virtual asset
activities; and
• Support the development of a safe, transparent, and well-supervised environment for virtual asset
innovation in Trinidad and Tobago.

Who is affected?

The Act applies to people or entities currently engaged in virtual asset activities as a business or on behalf
of others, including but not limited to:
• Exchange of virtual assets and domestic or foreign currencies;
• Exchange between virtual assets;
• Transfer of virtual assets; and
• Provision of financial services related to the issuance or sale of virtual assets.
Note that the Act does not permit holding/custody/retention of virtual assets on behalf of another person
as a virtual asset activity.

Further, the temporary prohibition does not apply to individuals using virtual assets for personal transactions such as the purchase of goods and services, provided such activity is not conducted as a business.

Obligations and deadlines

Persons or entities operating as Virtual Asset Service Providers (VASPs) prior to commencement of the VA/VASP Act are required to note the following statutory timelines:

• Within 30 days of commencement of the Act, affected VASPs must notify the TTSEC in writing
of their operations using the prescribed notification form. Affected VASPs must therefore notify
the TTSEC by/before January 22, 2026, of their operations.
• Eligible VASPs may apply for entry into the Regulatory Sandbox within the same 30-day period,
that is, by/before January 22, 2026.
• Where a VASP does not qualify for, or is not granted, entry into the Regulatory Sandbox, it must
cease virtual asset activities and notify the Commission of such cessation within fourteen days of
expiry of the three-month period, that is, by/before April 7, 2026.
• Failure to comply with the requirement in the VA/VASP Act to notify the TTSEC, cease operation,
where applicable, may attract significant administrative and criminal penalties.

Regulatory Sandbox

The regulatory sandbox provides a controlled framework under which eligible VASPs operating prior to enactment may be authorised by the TTSEC to conduct specified virtual asset activities, subject to strict conditions, supervision, and ongoing compliance with AML/CFT/CPF obligations.

Guidance documents, including the following, are available on the TTSEC’s website
https://www.ttsec.org.tt/industry/virtual-assets/

• Statutory forms
• Application instructions
• Eligibility criteria
• Fee schedules, and
• Fact Sheet

Applicants are required to submit requisite information and documentation to: Chief Executive Officer, Trinidad and Tobago Securities and Exchange Commission, Levels 22-23, Tower D International Waterfront Centre, 1 Wrightson Road, Port of Spain.

The email address is: vaspsandbox@ttsec.org.tt

The TTSEC encouraged people to review the information carefully and engage with the commission in a timely manner to ensure compliance.

About the TTSEC:

The SEC is governed by the Securities Act Chapter 83:02 and is responsible for overseeing the securities market and ensuring that fairness, equity and transparency remain common values in the marketplace.

The commission's vision is to be an innovative regulator of a thriving securities market, enabling economic development for the benefit of all.

The TTSEC's current board of commissioners include Imtiaz Hosein, chairman; Anthony Bullock, deputy chairman; Amerelle T.S. Francis; Angela D. Hordatt; Zahrah Mohammed; Christopher Sandy; Dr Marlene Murray and; Dr Dorian M. Noel.

The commission's CEO is Kester Guy, deputy CEO Lystra Lucillio and Glenis Potts is its general counsel.