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.