Virtual Asset Service Providers
DIRECTORS FOR CAYMAN VASPs
The Hash team has been actively involved in the development of the Cayman VASP regime and in industry bodies.
ACTIVELY INVOLVED IN THE DEVELOPMENT OF THE VASPs FRAMEWORK
Our founder chairs the Cayman Blockchain Association that is involved in every industry consultation. One of our directors led the development of Cayman’s VASP legislation and worked with the Ministry of Financial Services for 7 years. Hash also consulted with CIMA on the development of the Exchange and Custodian framework as part of phase 2 of the VASP roll out process.
CIMA has been explicit: directors need custody experience
CCSS
CIMA Stated, on multiple occasions, that VASP directors need specific technical and regulatory expertise, such as custody.
Petri Basson, Founder of Hash Directors, co-authored and previously chaired the CCSS (Cryptocurrency Security Standard). Samuel Jacques-Cloutier, Director at Hash Directors, is in the process of qualifying as a CCSS Auditor. This is not a credential we display for marketing. It is a requirement we meet.
What we do for VASPs
From application through ongoing licence operation
01
Independent directorship
Active board presence on the VASP entity. Documented decision-making. Ongoing oversight of licence conditions and operational changes.
02
AML and compliance Oversight
Working close with AML officers ensure full compliance with Cayman regs.
03
Regulatory engagement support
Working alongside Cayman counsel on the board’s interaction with CIMA before and after licensing.
04
Ongoing CIMA reporting governance
The board-level oversight of reporting obligations, working with the AMLCO, MLRO, auditors, and counsel.
Engagement stages
WE SEE VASPs AT TWO DISTINCT STAGES
Pre-licensing
Structuring the application. Board composition. Governance documentation. Custody architecture review. Coordinated with Cayman counsel, who lead the legal and regulatory work.
Post-licensing
Meeting CIMA’s ongoing expectations. Running the board properly. Handling material changes, audits, and inspections in a way that is documented and explainable.
VASP questions we hear most
Can you guarantee licence approval?
No. No legitimate provider can. Licensing decisions sit with CIMA. We help build the strongest, most credible governance and operational case the applicant can put forward, working alongside Cayman counsel.
DO YOU ACT AS AMLCO OR MLRO?
We work with trusted AML service providers, such as Provenance, our sister firm. Our role is at board level.
WHICH VASP CATEGORIES DO YOU WORK ACROSS?
Registration and licensing (Exchange and Custodian) categories under the VASP regime. We can confirm fit on a call based on the specific business.
DO YOU TAKE ON EARLY-STAGE APPLICANTS?
Yes, with the right fit. Earlier engagement often results in a stronger application. We are open about whether we believe an application is realistic.
HOW DO YOU HANDLE CONFLICTS ACROSS EXCHANGES, CUSTODIANS, AND PROJECTS?
Formally. Conflicts are mapped on engagement, reviewed periodically, and disclosed where relevant. Active management of conflicts is part of how an independent director earns the role.
