Virgin Islands (U.S.)
Retail_Trading_Status
- Analysis ID
- #826
- Version
- Archived
- Created
- 2025-12-12 05:24
- Run
- 63d1414a...
- History
- View all versions
- Workflow Stage
- Step 1
Executive Summary
Retail cryptocurrency trading is legal in the U.S. Virgin Islands (USVI), characterized by a unique regulatory stance where the local financial regulator explicitly disclaims jurisdiction while the economic development authority actively recruits crypto businesses. The Division of Banking, Insurance and Financial Regulation (DBIFR) has determined that cryptocurrency services do not fall under the Territory's Uniform Money Services Act, meaning no local license is currently required or available for crypto-only operators. Despite this local 'hands-off' approach, businesses and traders remain subject to U.S. federal regulations (FinCEN, IRS) and can qualify for significant local tax incentives through the University of the Virgin Islands Research and Technology Park (RTPark).
Key Pillars
Division of Banking, Insurance and Financial Regulation (DBIFR) (Primary Regulator - explicitly non-regulatory for crypto)
University of the Virgin Islands Research and Technology Park (RTPark) (Economic Development & Tax Incentives)
U.S. Federal FinCEN (AML/KYC oversight via MSB registration)
Bureau of Internal Revenue (BIR) (Local tax authority mirroring IRS rules)
Landmark Laws
Bulletin 2022-01: Licensure and Regulation of Cryptocurrency Services (Bulletin 2022-01) - Enacted: 2022-01-01
- Explicitly states that the Virgin Islands Uniform Money Services Act does not provide a framework to license cryptocurrency services. It declares cryptocurrency as a 'non-licensed product' and 'not regulated' by the Banking Board, refusing to process Money Transmitter applications for crypto-only entities.
- Source
Virgin Islands Uniform Money Services Act (Title 9, Chapter 22) - Enacted: 2019-01-01
- The primary law governing money transmission. The Banking Board has interpreted this law to exclude cryptocurrency services, thereby exempting them from local licensing requirements.
- Source
University of the Virgin Islands Research and Technology Park Act (Title 17, Chapter 34) - Enacted: 2002-01-01
- Establishes the RTPark and provides tax incentives (up to 90% income tax reduction) for qualifying technology and knowledge-based businesses, explicitly including blockchain and fintech companies.
- Source
Considerations
Federal Preemption: While locally unregulated, USVI is a U.S. territory, so FinCEN (AML) and OFAC sanctions apply fully.
Tax Incentives: The RTPark program offers aggressive tax breaks (90% reduction) for crypto businesses, creating a 'haven' environment despite the lack of prudential licensing.
Banking Access: Local banks may be hesitant to bank crypto firms due to the Banking Board's refusal to license/supervise them, pushing entities to rely on offshore or mainland U.S. banking partners.
No Consumer Protection: The DBIFR explicitly states it does not regulate crypto, meaning local consumer protection mechanisms for money transmission do not apply to crypto losses.
Notes
It is critical to distinguish the U.S. Virgin Islands (USVI) from the British Virgin Islands (BVI). The BVI has a comprehensive 'Virtual Assets Service Providers Act' (2022) and actively regulates the sector. The USVI, conversely, has explicitly stated it does not regulate the sector under its current Money Services Act. This analysis pertains strictly to the U.S. territory.
Remaining Uncertainties
- Whether the Banking Board will reverse its position and adopt the CSBS Model Law or similar framework in the future.
- How local banks treat crypto-related transactions given the lack of local regulatory 'blessing' or license.
- Potential confusion between USVI (unregulated) and BVI (highly regulated under VASP Act) by outside observers.
Full Analysis Report
Full Analysis Report
The regulatory status of cryptocurrency in the U.S. Virgin Islands (USVI) is classified as Allowed-UnRegulated due to a specific determination by the local financial regulator to exclude digital assets from its oversight. Unlike states such as New York (which requires a BitLicense) or most U.S. states (which regulate crypto under Money Transmitter Laws), the USVI Division of Banking, Insurance and Financial Regulation (DBIFR) issued Bulletin 2022-01, explicitly stating that the Territory's Uniform Money Services Act (UMSA) does not cover cryptocurrency. Consequently, the Banking Board declared that cryptocurrency is a 'non-licensed product' and that it 'will not approve or consider' money transmission applications for entities performing only cryptocurrency services.
This 'hands-off' approach by the prudential regulator creates a unique environment where crypto businesses do not require a local license to operate. However, this does not imply a lack of all oversight. As a U.S. territory, the USVI falls under the jurisdiction of federal agencies. Cryptocurrency exchanges and custodians operating in the USVI must register as Money Services Businesses (MSBs) with the U.S. Financial Crimes Enforcement Network (FinCEN) and comply with the Bank Secrecy Act (BSA), including AML and KYC obligations. The local exemption merely removes the additional layer of territorial licensing and bonding.
Contrasting with the DBIFR's passive stance, the University of the Virgin Islands Research and Technology Park (RTPark) actively incentivizes the sector. The RTPark, an economic development authority, markets the USVI as a hub for blockchain and fintech innovation. It offers qualifying businesses substantial tax benefits, including a 90% reduction in income tax liability and exemptions from gross receipts and excise taxes. This creates a bifurcation where the economic arm of the government promotes crypto while the financial regulator declines to supervise it.
Retail traders in the USVI face no legal restrictions on buying, selling, or holding digital assets. Major global exchanges and platforms serve the territory, often treating it similarly to a U.S. state for federal compliance purposes. However, the DBIFR's position means that local consumer protections inherent in the money transmission licensing regime (such as surety bonds and permissible investment requirements) do not apply to crypto assets held by local entities. Residents must rely on federal protections and the terms of service of the platforms they use.
The regulatory status of cryptocurrency in the U.S. Virgin Islands (USVI) is classified as **Allowed-UnRegulated** due to a specific determination by the local financial regulator to exclude digital assets from its oversight. Unlike states such as New York (which requires a BitLicense) or most U.S. states (which regulate crypto under Money Transmitter Laws), the USVI Division of Banking, Insurance and Financial Regulation (DBIFR) issued **Bulletin 2022-01**, explicitly stating that the Territory's *Uniform Money Services Act* (UMSA) does not cover cryptocurrency. Consequently, the Banking Board declared that cryptocurrency is a 'non-licensed product' and that it 'will not approve or consider' money transmission applications for entities performing only cryptocurrency services. This 'hands-off' approach by the prudential regulator creates a unique environment where crypto businesses do not require a local license to operate. However, this does not imply a lack of all oversight. As a U.S. territory, the USVI falls under the jurisdiction of federal agencies. Cryptocurrency exchanges and custodians operating in the USVI must register as Money Services Businesses (MSBs) with the U.S. Financial Crimes Enforcement Network (FinCEN) and comply with the Bank Secrecy Act (BSA), including AML and KYC obligations. The local exemption merely removes the additional layer of territorial licensing and bonding. Contrasting with the DBIFR's passive stance, the **University of the Virgin Islands Research and Technology Park (RTPark)** actively incentivizes the sector. The RTPark, an economic development authority, markets the USVI as a hub for blockchain and fintech innovation. It offers qualifying businesses substantial tax benefits, including a 90% reduction in income tax liability and exemptions from gross receipts and excise taxes. This creates a bifurcation where the economic arm of the government promotes crypto while the financial regulator declines to supervise it. Retail traders in the USVI face no legal restrictions on buying, selling, or holding digital assets. Major global exchanges and platforms serve the territory, often treating it similarly to a U.S. state for federal compliance purposes. However, the DBIFR's position means that local consumer protections inherent in the money transmission licensing regime (such as surety bonds and permissible investment requirements) do not apply to crypto assets held by local entities. Residents must rely on federal protections and the terms of service of the platforms they use.
Source Evidence
Primary and secondary sources cited in this analysis
"The Banking Board has determined the following, cryptocurrency is: (1) a non-licensed product in the Territory, (2) not specifically authorized under Title 9... and (3) not regulated by the Banking Board and the Division."
"Bulletin 2022-01 Licensure and Regulation of Cryptocurrency Services in the United States Virgin Islands"
"Up to 90% reduction in income tax liability... The RTPark is appropriate for fintech and blockchain businesses."
"United States Virgin Islands has not enacted regulations or legislation specifically regulating digital currency yet."
"U.S. Virgin Islands: None"
Web Sources (8)
Sources discovered via web search grounding
Search queries used (9)
- US Virgin Islands Uniform Money Services Act cryptocurrency
- US Virgin Islands cryptocurrency regulation retail trading status
- buying bitcoin in US Virgin Islands legal
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- USVI Division of Banking Insurance and Financial Regulation cryptocurrency license
- USVI Bulletin 2022-01 cryptocurrency status
- USVI RT Park cryptocurrency tax incentives
- buying bitcoin US Virgin Islands banks
- USVI Division of Banking Insurance and Financial Regulation crypto update 2024 2025
https://legvi.org/rt-park-and-casino-commission-highlight-millions-in-economic-contributions-and-community-impact/
https://www.walkersglobal.com/en/Insights/2025/08/British-Virgin-Islands-Crypto-asset-regulation
https://ltg.gov.vi/wp-content/uploads/2022/04/Bulletin-2022-01-Licensure-and-Regulation-of-Cryptocurrency-Services-in-the-United-States-Virgin-Islands.pdf
https://practiceguides.chambers.com/practice-guides/investing-in-2025/us-virgin-islands/trends-and-developments
https://f.hubspotusercontent10.net/hubfs/19504216/UvirtPark_April2021/PDFs/Summary_of_USVI_Tax_Incentives-9-29-15.pdf
https://www.applebyglobal.com/publications/blockchain-2025-guide-british-virgin-islands/
https://uvirtpark.net/invest
https://spectrocoin.com/bitcoin-cash-in-US-Virgin-Islands.html