Bonaire, Sint Eustatius and Saba

The regulatory status of cryptocurrency in Bonaire, Sint Eustatius, and Saba (the BES islands) is currently best classified as **Allowed-UnRegulated**. As special municipalities of the Netherlands, the islands fall under the supervision of the Dutch Central Bank (DNB) and the Dutch Authority for the Financial Markets (AFM). However, the legal framework in the BES islands is distinct from that of the European Netherlands. While the European Netherlands has implemented strict VASP registration requirements under the Wwft (implementing AMLD5) and is adopting MiCA, these regimes do not automatically extend to the BES islands, which hold Overseas Country and Territory (OCT) status.

The primary financial regulations in force are the *Wet financiële markten BES* (Wfm BES) and the *Wet ter voorkoming van witwassen en financieren van terrorisme BES* (Wwft BES). Current assessments, including those by the FATF and the Dutch government, indicate that while traditional financial institutions in BES are subject to AML/CFT rules, the specific legal provisions designating crypto service providers (VASPs) as 'obliged entities' requiring registration are still in the drafting phase. Consequently, there is no active public register of licensed BES-based crypto exchanges comparable to the DNB register for the European Netherlands.

Despite the lack of a formal licensing regime, the DNB and AFM actively monitor the sector. The DNB's website for the Caribbean Netherlands includes a section for 'Crypto service providers,' suggesting that supervision is a priority and that the regulatory gap is likely to be closed soon. Financial institutions operating in BES are already required to treat crypto assets as high-risk factors in their customer due diligence processes under the general Wwft BES obligations.

Retail traders in the BES islands can legally buy, sell, and hold cryptocurrencies. However, they typically rely on international platforms or those registered in the European Netherlands, as there are no local regulated exchanges. The official currency of the islands is the US Dollar, and DNB is working to ensure the stability of the payment system (including cash access), but crypto is not considered legal tender. Investors should be aware that they do not enjoy the same consumer protections (e.g., under MiCA) that apply within the European Union.