Trusted Legal Expertise in Procuring VASP License in Curacao
Successfully apply for a Curacao cryptocurrency license and unlock your business’ potential, with LegalBison’s expert assistance.
Quick Facts: Curacao VASP
| License Type | Virtual Asset Service Provider (VASP) / Dienstverlener |
| Regulator | Centrale Bank van Curaçao en Sint Maarten (CBCS) |
| Timeframe | 1 week for incorporation, 2-6 weeks for licensing |
| Government fees | Yes, as prescribed by CBCS to the applicant individually |
| Corporate tax | 0% |
| Minimum capital | Yes, as prescribed by CBCS to the applicant individually |
| Key advantages | Fast licensing process, low cost, offshore advantages, high-standing jurisdiction |
Curaçao has a developing reputation for being a forward-looking jurisdiction for international compliance and financial supervision. It’s only natural that this Dutch Caribbean island developed its own framework of crypto regulation. Curaçao is establishing itself as a secure financial center, which increases confidence among investors and partners regarding the safety of the sector.
This guide to the crypto license in Curaçao includes everything you need about one of the most up-to-date VASP frameworks in the world: how to start a licensed crypto company in Curaçao, what is the process and the requirements, and what is expected regarding compliance.
• Tax-free environment: Virtual Assets Services Providers in Curacao are exempt from corporate income taxes.
• Straightforward standards: The Central Bank (CBCS) has issued a clear framework aligned with FATF standards to combat money laundering and terrorist financing, ensuring global respectability.
• Fast complete set-up: A Curacao cryptocurrency licensed company can be fully formed and operational within 2 months. This is one of the shortest paths to reach the crypto business markets.
• Friendly fee structure: The minimum capital and applications fees are determined by the regulator, depending on the project individually.
Company incorporation and registration are the first steps to establish your business in Curaçao, as a license cannot be granted to a natural person. Most crypto businesses must organize as a legal entity to ensure they can meet the requirement of having at least two policymakers, one of whom must reside in Curaçao.
Legal experts in designing solutions for crypto licensing worldwide.
Former investment banker turned crypto & gambling regulation specialist.
Regulatory Overview: Virtual Assets Services Providers license in Curacao
The regulation of cryptocurrencies in Curacao remains relatively nascent. The government has stated that it is at the beginning of forming cryptocurrency regulation, with plans for future modifications to the laws as the legal framework continues to develop.
The enactment of the Landsverordening toezicht virtuele activa dienstverleners (VASP Act) on March 13, 2025, represents a definitive strategic pivot for Curacao, transforming the jurisdiction into an institutional-grade regulated hub. Curacao law forms the foundation of this new regulatory regime, establishing the evolving legal framework for crypto businesses.
Curacao is also tied to the European Union through its association with the Netherlands, but not a Member State. This partly influences its regulatory environment and the development of its legal framework.
For global operators, this legislation is the primary mechanism for aligning with FATF Recommendation 15 standards, effectively mitigating the “de-risking” crisis that has historically severed crypto-native firms from traditional banking rails. By replacing the 2024 mandatory registration phase with a rigorous licensing regime, Curacao provides the legal certainty required for long-term capital allocation and international expansion.
The Centrale Bank van Curaçao en Sint Maarten (CBCS) serves as the sole supervisory authority, possessing the exclusive mandate to oversee the market’s integrity and stability. This guide is designed to assist C-suite executives and compliance architects in navigating the transition to the 2025 formal regime, ensuring that operational structures meet the high bar of Dutch-Caribbean regulatory scrutiny.
The VASP Act provides the CBCS with the legal mandate to govern the sector through a centralized, high-transparency model.
- Scope of Authority (Article 3): The CBCS holds the power to decide on licenses, exemptions (vrijstellingen), dispensations (ontheffingen), and permissions (toestemmingen). This comprehensive authority ensures no segment of the virtual asset market operates in a regulatory vacuum. In addition, the Curacao Gambling Authority (CGA) will be responsible for compliance and regulation of new crypto license holders, further strengthening oversight within the evolving legal framework.
- Evasion of Supervision (Article 10): A critical refusal ground for the CBCS is the “evasion clause.” Under Article 10(a), the Bank will refuse a license if it has grounds to believe the applicant is seeking a Curacao license specifically to evade supervision in another country.
- AML/CFT Integration: The Act is legally tethered to the National Ordinance on Identification (LID) and Reporting of Unusual Transactions (MOT). Licensees are functionally equivalent to traditional banks regarding their duties to combat money laundering and terrorism financing.
- The Public VASP Register (Article 18): Transparency is maintained through a public register of all licensed and exempted entities, providing global counterparties with a “ground truth” for verifying the regulatory status of Curacao-based firms.
Precise activity definitions are the bedrock of operational compliance. Article 1 of the 2025 Act authorizes five core activities:
- Fiat-to-Crypto Exchange: Exchanging between virtual assets and fiduciary (fiat) currency;
- Crypto-to-Crypto Exchange: Exchanging between one or more forms of virtual assets;
- Transfer Services: The transfer of virtual assets on behalf of third parties;
- Custodial Services: The safekeeping or management of virtual assets or tools (private keys) to exercise control over them;
- Financial Services for Issuance: Providing services related to the offer, purchase, or sale of virtual assets (e.g., Token Sales/ICOs).
What are the key advantages of obtaining a Curacao cryptocurrency license
In the current global climate, regulatory clarity is a high-value competitive asset. Curacao offers a sophisticated environment that balances technological innovation with traditional financial rigor.
- Legal Certainty through “Landsverordening”: Unlike temporary measures, the 2025 Act provides a permanent legislative foundation, protecting businesses from the volatility of “regulation by enforcement” seen in other jurisdictions;
- Central Bank Pedigree: The CBCS oversees a dual jurisdiction (Curacao and Sint Maarten). While the 2025 VASP Act is currently specific to Curacao, the involvement of a Central Bank that manages two financial systems adds significant regional prestige and professional standing to any license held;
- Cost-Effective and Fast Market Entry: The crypto license in Curacao offers a cost-effective and relatively fast entry point for crypto businesses into the global market;
- Legitimacy and User Trust: Operating with a government-issued license from Curacao provides legitimacy, which is critical for user trust and partnerships with banks;
- Tax Advantages: Curacao has no capital gains, dividend, or inheritance tax, making it attractive for entrepreneurs launching crypto projects;
- Lower Operational Costs: The operational costs of running a crypto business in Curacao are significantly lower compared to other jurisdictions, including licensing, office rent, employee wages, and compliance requirements, attracting startups and entrepreneurs.
Different types of crypto licenses in Curaçao and the covered activities
The National Ordinance on the Supervision of Virtual Asset Service Providers (effective 2025) defines the main crypto activities that require a license to be performed by a company.
While there is a single license category, the obligations differ based on whether you intend:
- to operate a virtual assets exchange (exchanging between virtual assets and fiat, or between forms of virtual assets);
- to engage in the business of providing custody (safekeeping and administration) of virtual assets or access means.
Both of these activities require the payment of application and annual supervision fees, which are legally mandated to cover the Central Bank’s actual costs rather than a flat tax.
On the application side, what will differ is the specific operational compliance required by the regulator. In the case of a custodial company, requirements in terms of segregating client assets from the company’s own funds and liability for loss of assets due to hacks will be the most important.
The Ordinance also describes other types of activity that encompass transfer services and financial services related to the issuance and sale of virtual assets.
For companies willing to provide a new and innovative service, such as issuing their own token, the law provides a specific framework for Issuers. This specific regulation requires the publication of a “white paper” approved by the Bank to ensure the project acts honestly and professionally. Furthermore, the Central Bank has the authority to grant exemptions or dispensations from certain rules if the applicant demonstrates that the objectives of the law are otherwise met, offering flexibility for unique business models.
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What are the application requirements for a Curacao VASP License
| Duration | from 7 weeks |
| Local office | Registered office only |
| Local director | At least two persons must determine daily policy, and at least one must reside in Curaçao. |
| Accounting and auditing | Yes, annual accounts must be audited by an external expert and submitted to the Bank. |
| Economic substance | Requires local residence of a policymaker and safeguarding of client funds. |
| Government fee | Yes (Cost-based): Fees are legally mandated to cover only the actual costs of supervision and processing, not for profit. |
| Corporate income tax (CIT) | 0% |
| Withholding tax (WHT) | 0% |
The CBCS employs a “fit and proper” standard that mirrors the governance expectations of traditional credit institutions.
- Governance & Substance: The “Four-Eyes Principle” is mandatory. At least two managers must direct the daily policy, with at least one residing in Curacao. This ensures that the entity maintains a physical and decision-making “seat” (zetel) within the jurisdiction. While a physical presence is not always mandatory, having a local office or a local director is generally required for compliance purposes when applying for a cryptocurrency license in Curacao. The licensing process in Curacao also requires a local legal entity to be established, which involves preparing comprehensive documents, appointing local directors, and complying with jurisdiction-specific regulations;
- Suitability & Integrity: “Geschiktheid” (suitability) and “Betrouwbaarheid” (integrity) testing is not limited to management; it extends to the Members of the Supervisory Board (Raad van Commissarissen) and Ultimate Beneficial Owners (UBOs);
- Required Documents: The application for a cryptocurrency license in Curacao must include a complete set of required documents. Applicants must submit a corporate information form as part of the required documents for the licensing process. This standardized document must be completed and signed by an official company representative and serves as an essential part of verifying business details;
- Financial Safeguards & Asset Segregation: To protect client assets from the VASP’s own creditors, the Act mandates strict segregation. Licensees must use a “Stichting Derdengelden” (Foundation for Third-Party Funds) or a dedicated “bewaarrekening” (custodial account) at a bank to hold fiduciary funds.
What is the step-by-step crypto licensing process in Curacao?
The process to get licensed as a crypto business in Curaçao is structured. In three steps, you can have your own crypto licensed company set and ready in this Dutch Caribbean jurisdiction.
Company incorporation, registration, and application preparation are among such services necessary for successfully obtaining a Curaçao VASP license.
INCORPORATION OF A COMPANY IN CURAÇAO
The crypto license can only be granted to a legal entity, not a natural person. Incorporation is therefore step number one.
- Legal entity registration in Curacao;
- Share capital must be sufficient to meet the “minimum own funds” and solvency requirements determined individually by the Bank;
- Contract with a resident policymaker: At least one of the persons determining daily policy must reside in Curacao;
- Your team must provide copies of passports and personal questionnaires for the “Fit and Proper” assessment.
PREPARATION OF THE APPLICATION FOR THE VASP LICENSE
The requirements of the Central Bank (CBCS) pertaining to the Curaçao crypto license are comprehensive. Careful preparation is key to getting the license. As part of the application, a clear business model must be described, detailing the company’s business activities and governance structure.
- Crafting AML-KYC policies compliant with the NOIS and NORUT ordinances;
- Development and audit of the IT and network infrastructure;
- Appointment of a Compliance Officer to independently monitor adherence to legal rules;
- A detailed description of the software, technology, and wallet management procedures;
- Risk management framework identifying operational and financial risks;
- Provisions to protect consumer data and handle complaints.
APPLICATION TO THE CENTRAL BANK FOR THE CRYPTO LICENSE
Once the company is ready to apply, it carries out its request for a crypto license in Curaçao. The Central Bank decides within 60 days of receiving a complete application. The license is required for conducting business involving virtual assets in or from Curaçao.
- Demonstrating sufficient solvency and minimum own funds to ensure financial reliability;
- Provision of a detailed business plan including strategy, cash flow, and a recovery/resolution plan;
- Presentation of the board and shareholders, including the ownership structure and ultimate beneficial owners (UBOs);
- Demonstration of fitness and propriety (expertise and integrity) of the policymakers and holders of qualifying holdings;
- Provide outsourcing agreements if critical activities are delegated to third parties;
- Demonstration of business continuity, explaining how customer assets are segregated from the company’s own funds to protect against bankruptcy.
Costs and fees for a Curacao VASP License
Once the application is ready, the VASP applicant must pay a fee to the Central Bank (CBCS) which is legally mandated to be cost-neutral, covering only the actual expenses of the regulator.
To provide any Virtual Assets Service (including Custody or Exchange), the application fee is established by National Decree and charged immediately upon receipt of the application.
To maintain the license, the VASP must pay an annual supervision fee, the amount of which is calculated to equal at most the costs incurred by the Bank for exercising supervision.
These fees are based on direct and indirect costs incurred by the VASP applicant and may be adjusted annually based on the consumer price index. This approach means there is no fixed sum applicable for all applicants, and that the CBCS decided to adapt its fee structure to the size and capacity of each applicant.
Taxation for cryptocurrency companies in Curacao
Curacao does not levy corporate income taxes on virtual assets service providers’ activities.
There are also no withholding taxes. Dividends shall only be taxable in the residence country of the shareholder receiving a dividend payment.
Compliance and maintenance requirements after securing a Curacao crypto license
Curaçao mandates a Risk-Based Approach (RBA). The August 2024 Provisions & Guidelines (issued for Securities Intermediaries and Asset Managers) reflect the compliance pillars required under the National Ordinance on the Reporting of Unusual Transactions (MOT) and the National Ordinance on Identification when Rendering Services (LID), which also apply to VASPs:
- Customer Due Diligence (CDD): Verification of natural and legal persons is required before rendering services, including the mandatory identification of the Ultimate Beneficial Owner (UBO);
- Enhanced Due Diligence (EDD): Mandatory for high-risk clients, including Politically Exposed Persons (PEPs) and transactions involving FATF-listed high-risk jurisdictions or countries with strategic AML/CFT deficiencies;
- Transaction Monitoring: Continuous scrutiny is required to ensure activities align with the client’s risk profile and to verify the source of wealth and funds;
- Reporting Obligations: Any “Unusual Transaction” (or intended transaction) must be reported immediately to the Financial Intelligence Unit (FIU) under the MOT.
Common misconceptions about the Curacao VASP license
No, “there is no specific regulations for crypto in Curacao” is not true anymore. Since 2025, Curacao regulates crypto companies as Virtual Assets Services Providers. Most of the information found on the internet are critically outdated.
No, there are no relationships between the VASP framework and the Curacao Gaming Board. The VASP regime is managed by the Central Bank of Curacao and Sint Maarten (CBCS).
What are the texts composing the legal framework of the Curacao cryptocurrency license
The cryptocurrency regulation in Curaçao is now fully relying on the National Ordinance on the Supervision of Virtual Asset Service Providers (Landsverordening toezicht virtuele activa dienstverleners). It details the requirements and obligations of cryptocurrency-related companies, to secure and maintain the Curaçao crypto license.
These requirements are tied to another set of laws, which are relative to anti-money laundering, countering terrorism financing, and combating financial crime:
- National Ordinance on Identification when Rendering Services (LID/NOIS);
- National Ordinance on the Reporting of Unusual Transactions (MOT/NORUT);
- Sanctions National Ordinance (Sanctielandsverordening) and the Kingdom Sanction Law (Rijkssanctiewet).
The regulations pertaining to crypto in Curaçao are therefore combining a dedicated law, the VASP supervision ordinance, and acts regarding AML-CFT and KYC.
Costs and fees for a Curacao VASP License
Once the application is ready, the VASP applicant must pay a fee to the Central Bank (CBCS) which is legally mandated to be cost-neutral, covering only the actual expenses of the regulator.
To provide any Virtual Assets Service (including Custody or Exchange), the application fee is established by National Decree and charged immediately upon receipt of the application.
To maintain the license, the VASP must pay an annual supervision fee, the amount of which is calculated to equal at most the costs incurred by the Bank for exercising supervision.
These fees are based on direct and indirect costs incurred by the VASP applicant and may be adjusted annually based on the consumer price index. This approach means there is no fixed sum applicable for all applicants, and that the CBCS decided to adapt its fee structure to the size and capacity of each applicant.
Taxation for cryptocurrency companies in Curacao
Curacao does not levy corporate income taxes on virtual assets service providers’ activities.
There are also no withholding taxes. Dividends shall only be taxable in the residence country of the shareholder receiving a dividend payment.
Compliance and maintenance requirements after securing a Curacao crypto license
Curaçao mandates a Risk-Based Approach (RBA). The August 2024 Provisions & Guidelines (issued for Securities Intermediaries and Asset Managers) reflect the compliance pillars required under the National Ordinance on the Reporting of Unusual Transactions (MOT) and the National Ordinance on Identification when Rendering Services (LID), which also apply to VASPs:
- Customer Due Diligence (CDD): Verification of natural and legal persons is required before rendering services, including the mandatory identification of the Ultimate Beneficial Owner (UBO);
- Enhanced Due Diligence (EDD): Mandatory for high-risk clients, including Politically Exposed Persons (PEPs) and transactions involving FATF-listed high-risk jurisdictions or countries with strategic AML/CFT deficiencies;
- Transaction Monitoring: Continuous scrutiny is required to ensure activities align with the client’s risk profile and to verify the source of wealth and funds;
- Reporting Obligations: Any “Unusual Transaction” (or intended transaction) must be reported immediately to the Financial Intelligence Unit (FIU) under the MOT.
Common misconceptions about the Curacao VASP license
No, “there is no specific regulations for crypto in Curacao” is not true anymore. Since 2025, Curacao regulates crypto companies as Virtual Assets Services Providers. Most of the information found on the internet are critically outdated.
No, there are no relationships between the VASP framework and the Curacao Gaming Board. The VASP regime is managed by the Central Bank of Curacao and Sint Maarten (CBCS).
What are the texts composing the legal framework of the Curacao cryptocurrency license
The cryptocurrency regulation in Curaçao is now fully relying on the National Ordinance on the Supervision of Virtual Asset Service Providers (Landsverordening toezicht virtuele activa dienstverleners). It details the requirements and obligations of cryptocurrency-related companies, to secure and maintain the Curaçao crypto license.
These requirements are tied to another set of laws, which are relative to anti-money laundering, countering terrorism financing, and combating financial crime:
- National Ordinance on Identification when Rendering Services (LID/NOIS);
- National Ordinance on the Reporting of Unusual Transactions (MOT/NORUT);
- Sanctions National Ordinance (Sanctielandsverordening) and the Kingdom Sanction Law (Rijkssanctiewet).
The regulations pertaining to crypto in Curaçao are therefore combining a dedicated law, the VASP supervision ordinance, and acts regarding AML-CFT and KYC.
FAQ – Curacao Crypto License
After sending the application to the CBCS, the process usually takes between 2 and 6 weeks. This is one of the shortest licensing timeline for cryptocurrency businesses.
Yes, you can offer USDT (Tether) as a VASP registered in Curaçao. The EU ban on this specific stablecoin does not apply in Curacao.
LegalBison has formulated a packaged offer for crypto entrepreneurs and companies interested in setting up a company in Curacao. We encourage you to get in touch with our consulting team for more information and a quote.
Yes, you can operate both a crypto (VASP) and a gambling licensed business in Curaçao, but whether you can “cumulate” them within a single legal entity depends on the specific nature of your operations and the requirements of the Central Bank (CBCS). LegalBison usually advises to create separate entities, in order to avoid creating a single point of failure and for corporate structuring fluidity.
Yes, as a Virtual Asset Service Provider (VASP) in Curacao, you are legally required to appoint an AML/Compliance Office and a Representative Manager, both residing in Curacao. LegalBison assists in fulfilling these requirements efficiently.
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Contact us today for a free consultation. Together with our expert consultants and lawyers, you will assess the cost of a license for your project, particular requirements, and the timeline.
Legal experts in designing solutions for crypto licensing worldwide.
Former investment banker turned crypto & gambling regulation specialist.