Re-thinking the T&T Virtual Assets Bill, 2025

Trinidad & Tobago’s Virtual Assets Bill, 2025 proposes a virtual assets moratorium until 2027. Explore its legal, economic and innovation impacts and calls for smarter regulation.

The Bill

On September 12th, 2025, the Government of Trinidad & Tobago introduced the Virtual Assets and Virtual Asset Service Providers Bill, 2025 in the T&T Parliament. This Bill aims to bring the country in line with Financial Action Task Force (FATF) Recommendations 15 and 16, which target anti-money laundering and counter-terrorism financing in the virtual assets space.

But the major catch is that the proposed legislation inter alia includes a moratorium on virtual assets activity until December 31, 2027, with penalties of up to TT$5 million for unauthorised operations.

Legal Recognition of Crypto Assets

Crypto assets are no longer fringe instruments. As noted by Aditya Narain and Marina Moretti, they have evolved into mainstream tools for investment, payments, weak currency hedging and payment instruments.

Additionally, Courts across the Commonwealth including The British Virgin Islands, Singapore, Hong Kong, Canada, Australia and New Zealand and the United Kingdom have recognised crypto as property. In AA v Persons unknown [2020] 4 WLR 35, Bitcoin was deemed a form of property capable of being the subject of an interim proprietary injunction.

And Section 4(a) of the Constitution of Trinidad & Tobago, guarantees the right to enjoyment of property and protection of the law. This therefore raises questions about the Bill’s impact on current owners of virtual assets, including cryptocurrency, “in or from within Trinidad & Tobago”.

T&T Crypto Activity is not just speculation

According to Chainalysis’ 2024 Geography of Crypto Report, Trinidad & Tobago had an overall rank of #137 in the Global Crypto Adoption Index which is proof that cryptocurrency is alive and well in T&T.

And this crypto activity isn’t just scams and speculation as it includes:

  • Micro, small, and medium enterprises (MSMEs)
  • Unbanked and underbanked individuals
  • Forex-starved businesses and individuals
  • Tech innovators and digital entrepreneurs

What this Bill Signals to Good Actors

If passed as-is, the Bill could force legitimate crypto businesses to pause operations until 2027, disrupting:

  • Customer services
  • Employee livelihoods
  • Contractor relationships
  • Financial inclusion efforts
  • Innovation and entrepreneurship

This raises a critical question – Is this proposed legislation aligned with T&T’s goals for digital transformation, economic diversification, foreign direct investment and forex generation?

A Call for Smarter Regulation

Rather than a blanket freeze, T&T needs a data-driven, inclusive approach to crypto regulation. That means:

  • Consulting and collaborating with industry stakeholders
  • Studying more regional and international comparators
  • Balancing compliance with innovation
  • Protecting consumers without stifling growth

Hope for the Future

To shape a future where compliance, creativity and innovation go hand in hand, lawmakers can go back to the drawing board and amend the Bill so that it:

  • Encourages ethical crypto innovation
  • Supports MSMEs
  • Aligns with global standards; and
  • Positions T&T as a regional leader in alternative finance.

For more commentary on this Bill stay tuned to this blog and also follow our Principal Attorney on LinkedIn or Substack.

And if this information resonates with you; or you need legal assistance navigating this area, feel free to reach out at info@tenorequelegalandconsulting.com. You can also explore these resources – About the 2025 Virtual Assets Bill, Track The Bill’s Progress in The Parliament Here, Follow via Livestream of the Parliament’s YouTube Channel, The Bill Essentials, Compliance or Collapse for our Crypto Future, “De-risking, Re-risking & Financial Crime in this era of alternative finance” by Bellina Barrow, “The Unrealised Benefits of the Crypto” Sector by Bellina Barrow, The Commonwealth Fintech Toolkit, The Central Bank of Trinidad & Tobago and the Financial Intelligence Unit of Trinidad and Tobago for more information.

T&T VIRTUAL ASSETS BILL 2025

Explore the Trinidad and Tobago Virtual Assets Bill 2025 – penalties, compliance and what businesses need to know.

 

Trinidad & Tobago is now signalling a future with explicit, specialised legislation for virtual assets activities, under the watchful, primary eyes of the Trinidad & Tobago Securities & Exchange Commission (TTSEC).  However, authorisation for wallet service provider and virtual asset activity will not be granted before 31st December 2027.

On 12th September 2025, there was the First Reading of The Virtual Assets and Virtual Assets Service Providers Bill, 2025 in the Trinidad & Tobago Parliament by The Honourable Davendranath Tancoo, Minister of Finance and Minister in the Ministry of Planning, Economic Affairs and Development. According to The Bill Essentials, this Bill seeks to reflect the framework set out by the Financial Action Task Force (FATF) Recommendations 15 and 16 particularly in relation to combatting money laundering, terrorist financing and proliferation.

FATF Recommendation 15 relates to “New Technologies” and Recommendation 16 relates to the “Travel Rule”. Taking this long overdue step towards international financial compliance was critical because as far back as 2019, FATF extended its anti-money AML/CFT measures to virtual assets (VA) and virtual asset service providers (VASPs) to prevent criminal and terrorist misuse of this sector.

 Lawmaking in a nutshell

A proposal for a new law can be initiated in either House – the House of Representatives or the Senate. However, a Bill must be passed by both Houses. All “money” Bills must originate in the House of Representatives and be sponsored by the Cabinet.

A Bill goes through various stages including being passed by the House of Representatives, the Senate and the President. The President must assent to all Bills passed by both Houses of Parliament before they can become law, and when a Bill is assented to, it becomes an Act of Parliament (law).

Once this Virtual Assets and Virtual Assets Service Providers Bill, 2025 is passed it will come into effect on a date fixed by the President for Proclamation.

About The Virtual Assets and Virtual Assets Service Providers Bill, 2025

This Bill is proposing to regulate virtual assets and virtual assets service providers via a very concise Bill of only ten (10) clauses, and the comparative legislation that was used to draft this Bill is the Bahamas Digital Assets and Registered Exchanges Act, 2024 (DARE 2024).

The Bill includes a very limited list of definitions. Of note are the definitions for distributed ledger technology, virtual assets, virtual asset activities, Virtual Asset Service Provider/VASP and Wallet Service Provider.

Some Prohibitions and Penalties in The Bill

The Bill says very little of what can be done but moreso emphasises what cannot be done and imposes some stiff penalties.

Among other provisions, the Bill proposes to:

  • Restrict engaging in virtual asset activities, in or from within T&T, without authorisation from the TTSEC.
  • Prohibit unauthorised exchange, transfer, safekeeping or administration of virtual assets, and participating in and provision of financial services related to virtual assets
  • Prohibit advertising virtual asset services except it is a person authorised by TTSEC.
  • Impose penalties including but not limited to:
  • A fine of TT$5 million and imprisonment up to 5 years for individuals, officers and directors of companies, officers or members of unincorporated bodies if liable on summary conviction for operating before the commencement of the Act and failing to write and notify the TTSEC of their operation within three (3) months of the commencement of the Act.
  • Additional daily fines for continuing offences.
  • A fine of TT$125,000 and 1-year imprisonment for virtual assets activity advertising etc.

For enterprising, innovative, law-abiding actors in the virtual assets ecosystem, especially micro, small and medium-sized enterprises, the Bill doesn’t appear to foreshadow a fostering of fertile ground for the growth of the industry. It fails to explore and unearth the untapped opportunity for driving innovation, revenue generation, foreign direct investment, earning much needed foreign exchange, the possibility for establishing virtual assets zones (as was proposed in Pakistan) etc. (all of which the sector can facilitate and foster once it is comprehensively studied, understood and all relevant stakeholders engaged). 

 What’s next?

Stakeholders in the local virtual assets sector should feel free to express their views, on this Bill, as they see fit. They also need to stay vigilant, take heed and be proactive about getting and remaining compliant, in the event this Bill becomes law, since it contains transitional provisions that existing operators need to take heed of and abide by within the stipulated time periods.

For more commentary on this Bill stay tuned to this blog and also follow our Principal Attorney on Substack.

And if this information resonates with you; or you need legal assistance navigating this area, feel free to reach out at info@tenorequelegalandconsulting.com. You can also explore these resources – Track The Bill’s Progress in The Parliament Here, Follow via Livestream of the Parliament’s YouTube Channel, The Bill Essentials, Crypto Scams, Crimes & The Courts, “De-risking, Re-risking & Financial Crime in this era of alternative finance” by Bellina Barrow, “The Unrealised Benefits of the Crypto” Sector by Bellina Barrow, The Commonwealth Fintech Toolkit, The Central Bank of Trinidad & Tobago and the Financial Intelligence Unit of Trinidad and Tobago for more information.