Trinidad and Tobago
Retail_Trading_Status
- Analysis ID
- #810
- Version
- Archived
- Created
- 2025-12-12 05:20
- Run
- 82a5b086...
- History
- View all versions
- Workflow Stage
- Step 1
Executive Summary
As of December 2025, Trinidad and Tobago has enacted the Virtual Assets and Virtual Assets Service Providers Act, 2025, which establishes a regulatory framework but imposes a moratorium on issuing licenses until December 31, 2027. While the legislation technically legalizes the asset class and creates a path for future regulation, the current 'transitional restrictions' effectively prohibit the operation of local crypto exchanges and wallet providers for the next two years. Retail trading is severely restricted due to the lack of licensed local providers and widespread banking blocks on foreign crypto transactions.
Key Pillars
Trinidad and Tobago Securities and Exchange Commission (TTSEC) (Primary Regulator)
Central Bank of Trinidad and Tobago (CBTT) (Payment Systems & E-Money)
Financial Intelligence Unit of Trinidad and Tobago (FIUTT) (AML/CFT Supervision)
Joint Regulatory Hub (Coordination between TTSEC, CBTT, and FIUTT)
Moratorium on VASP Licensing (Until Dec 31, 2027)
Landmark Laws
Virtual Assets and Virtual Assets Service Providers Act, 2025 (Bill No. 9 of 2025) - Enacted: 2025-11-21
- Establishes a licensing regime for virtual asset service providers (VASPs) but includes a transitional clause prohibiting the TTSEC from granting authorizations until December 31, 2027. Imposes fines of up to $5 million for unauthorized business activities.
- Source
E-Money Issuer Order, 2020 (Legal Notice No. 284 of 2020) - Enacted: 2020-08-04
- Allows non-bank entities to issue 'e-money' (digital fiat) under Central Bank supervision. Explicitly distinct from virtual assets/crypto; used for services like PayWise.
- Source
Securities Act, 2012 (Chap. 83:02) - Enacted: 2012-12-31
- Governs securities market. TTSEC uses this to regulate cryptocurrencies that qualify as 'investment contracts' or securities, requiring registration.
- Source
Considerations
Moratorium on Licenses: No local VASP licenses will be issued until Dec 31, 2027, creating a de facto ban on domestic exchanges.
Banking Blockade: Commercial banks generally refuse to process transactions related to cryptocurrency due to de-risking policies.
Taxation: Despite the restrictions on services, capital gains from crypto trading are taxable, and the Revenue Authority requires reporting.
FATF Compliance: The 2025 Act was rushed to meet the March 2026 Caribbean Financial Action Task Force (CFATF) mutual evaluation deadline.
Penalties: Operating a crypto business without a license carries severe penalties ($5M fine, 5 years imprisonment).
Notes
The analysis assumes the 'Current Time' of Dec 12, 2025. The regulatory landscape is in a state of flux following the very recent passage of the VASP Act. The 'Gray-Zone' status reflects the unique situation of having a law that regulates the sector by temporarily closing it.
Remaining Uncertainties
- The exact text of the 200+ amendments passed on Nov 21, 2025, is not yet publicly indexed; confirmation is needed on whether the '2027 moratorium' date was altered or kept as is.
- Whether the 'transitional restrictions' allow for a sandbox environment for select entities before 2027.
- The extent to which individual peer-to-peer trading is actively policed or criminalized under the 'unauthorized activity' clauses.
Full Analysis Report
Full Analysis Report
As of December 12, 2025, the regulatory status of retail cryptocurrency trading in Trinidad and Tobago is best classified as a 'Gray-Zone' with significant restrictive elements. The Parliament passed the Virtual Assets and Virtual Assets Service Providers Act, 2025 in late November 2025, marking the country's first dedicated legislation for the sector. However, rather than immediately opening the market, the Act includes a controversial 'transitional restriction'—effectively a moratorium—that prohibits the Trinidad and Tobago Securities and Exchange Commission (TTSEC) from granting licenses to Virtual Asset Service Providers (VASPs) until December 31, 2027. This approach aims to allow regulators time to build supervisory capacity while technically having a law on the books to satisfy international AML/CFT standards.
The practical implication for retail investors is a near-total absence of legal, local avenues to buy or sell cryptocurrencies. The Act criminalizes the operation of unauthorized virtual asset businesses with fines up to $5 million and imprisonment, forcing any remaining local operators to shut down or move underground. While the legislation targets 'business' activities (exchanges, custodians, wallet providers) rather than individual holding or peer-to-peer transfers, the ecosystem for safe trading has been dismantled for the interim period.
The Central Bank of Trinidad and Tobago (CBTT) has maintained a cautious stance, supporting the moratorium due to concerns over financial stability and consumer protection. The CBTT, TTSEC, and the Financial Intelligence Unit (FIUTT) collaborate through a 'Joint Regulatory Hub' to monitor the sector, but their current focus is on enforcement of the ban on unauthorized providers rather than facilitation. The banking sector reinforces this restrictiveness, with most commercial banks blocking transactions to known crypto exchanges to avoid de-risking penalties.
Despite the operational freeze, the legal classification of cryptocurrency has shifted from 'unregulated' to 'regulated but restricted.' The government acknowledges virtual assets as a property class for tax purposes, and the Trinidad and Tobago Revenue Authority expects citizens to report capital gains from crypto transactions. The rush to pass the 2025 Act was largely driven by the upcoming Caribbean Financial Action Task Force (CFATF) mutual evaluation in March 2026, forcing the government to demonstrate legislative progress even if full implementation is delayed until 2028.
As of December 12, 2025, the regulatory status of retail cryptocurrency trading in Trinidad and Tobago is best classified as a 'Gray-Zone' with significant restrictive elements. The Parliament passed the *Virtual Assets and Virtual Assets Service Providers Act, 2025* in late November 2025, marking the country's first dedicated legislation for the sector. However, rather than immediately opening the market, the Act includes a controversial 'transitional restriction'—effectively a moratorium—that prohibits the Trinidad and Tobago Securities and Exchange Commission (TTSEC) from granting licenses to Virtual Asset Service Providers (VASPs) until December 31, 2027. This approach aims to allow regulators time to build supervisory capacity while technically having a law on the books to satisfy international AML/CFT standards. The practical implication for retail investors is a near-total absence of legal, local avenues to buy or sell cryptocurrencies. The Act criminalizes the operation of unauthorized virtual asset businesses with fines up to $5 million and imprisonment, forcing any remaining local operators to shut down or move underground. While the legislation targets 'business' activities (exchanges, custodians, wallet providers) rather than individual holding or peer-to-peer transfers, the ecosystem for safe trading has been dismantled for the interim period. The Central Bank of Trinidad and Tobago (CBTT) has maintained a cautious stance, supporting the moratorium due to concerns over financial stability and consumer protection. The CBTT, TTSEC, and the Financial Intelligence Unit (FIUTT) collaborate through a 'Joint Regulatory Hub' to monitor the sector, but their current focus is on enforcement of the ban on unauthorized providers rather than facilitation. The banking sector reinforces this restrictiveness, with most commercial banks blocking transactions to known crypto exchanges to avoid de-risking penalties. Despite the operational freeze, the legal classification of cryptocurrency has shifted from 'unregulated' to 'regulated but restricted.' The government acknowledges virtual assets as a property class for tax purposes, and the Trinidad and Tobago Revenue Authority expects citizens to report capital gains from crypto transactions. The rush to pass the 2025 Act was largely driven by the upcoming Caribbean Financial Action Task Force (CFATF) mutual evaluation in March 2026, forcing the government to demonstrate legislative progress even if full implementation is delayed until 2028.
Source Evidence
Primary and secondary sources cited in this analysis
"An Act to regulate the conduct of business concerning Virtual Assets and Virtual Assets Service Providers... Status: House of Representatives - Senate Amendments."
"The Central Bank expressed its support for the proposed bill, which seeks to ban all virtual asset activity... until 2027."
"Providers of virtual currency are neither regulated nor supervised by the Central Bank, the TTSEC or the FIUTT."
"E-money issuer means a person... who is registered... to issue e-money."
"The Virtual Assets and Virtual Assets Service Providers Bill, 2025... sets out a framework for licensing... with transitional restrictions before full authorisations are issued."
"Clause 4 (3) of the Bill states that... the T&T Securities and Exchange Commission 'shall not, on or before December 31, 2027, grant any authorisation...'"
Web Sources (5)
Sources discovered via web search grounding
Search queries used (14)
- Trinidad and Tobago crypto tax laws
- Trinidad and Tobago cryptocurrency regulation status 2024 2025
- Central Bank of Trinidad and Tobago cryptocurrency policy
- TTSEC cryptocurrency guidelines Trinidad
- FIUTT VASP registration Trinidad and Tobago
- Trinidad and Tobago crypto trading legal status December 2025
- Trinidad "Virtual Assets and Virtual Assets Service Providers Bill" 2025 ban 2027
- Central Bank of Trinidad and Tobago crypto ban 2027
- "Colm Imbert" Trinidad crypto bill amendments November 2025
- "Virtual Assets and Virtual Assets Service Providers Act 2025" Trinidad status
- Trinidad and Tobago crypto tax 2025
- "E-Money Issuer Order" Trinidad crypto
- Trinidad and Tobago "Virtual Assets and Virtual Assets Service Providers Act 2025" text
- TTSEC "Joint Regulatory Hub" crypto
https://www.commonwealthlawyers.com/cla/de-risking-re-risking-financial-crime-in-this-era-of-alternative-finance-by-bellina-barrow/
https://www.lightspark.com/knowledge/is-crypto-legal-in-trinidad-and-tobago
https://www.crowdfundinsider.com/2025/11/255844-trinidad-and-tobago-passes-crypto-bill-ahead-of-fatf-review/
https://printery.gov.tt/e-gazette/2025/Gazette/Gazette_No._155_of_2025.pdf
https://printery.gov.tt/e-gazette/2025/Gazette/Gazette_No._155_of_2025.pdf