The Six VASP Licence Classes in Jamaica: Which One Does Your Business Need?

A practical decision guide to Classes A through F — what each one covers, the activity that triggers it, the obligations that come with it, the annual fee, and how to scope the right licence (or licences) before you spend.

 

In short: Jamaica’s proposed VASP regime creates six licence classes — A (trading platforms), B (advisory), C (custody), D (broker-dealer), E (wallet services) and F (conversion). Your class is determined by what you actually do for clients, not by what you call yourself. A separate licence is required for each class of activity you carry on, and each class carries its own annual fee, so a business that spans several activities pays for several licences. Most operators need one or two classes; the key is to map your business model to the right class (or classes) before you build, capitalise and apply.

What are the six VASP licence classes?

The Licensing Requirements define six categories of regulated virtual-asset activity. Each is a distinct licence with its own conditions and its own annual fee. The table below summarises all six, including the indicative annual fee and the signature obligation that most distinguishes each class.

Class	Category	Core activity	Annual fee	Signature obligation
A	Trading Platform Operator (exchange)	Matching buy and sell orders for virtual assets	J$4,000,000	Listing policy, surveillance, proof of reserves
B	Advisory Services	Advising clients on virtual assets	J$500,000	Client suitability assessment
C	Custody Services	Safekeeping and administration of client assets	J$400,000	Cold storage, key management, proof of reserves
D	Broker-Dealer	Dealing as principal or agent for clients	J$1,600,000	Client appropriateness assessment
E	Wallet Services	Wallet infrastructure to store and transfer assets	J$2,400,000	Cold storage, key management
F	Conversion Services	Converting between virtual assets, or to and from fiat	J$800,000	AML/CFT and Travel Rule controls

A one-off application processing fee of J$800,000 also applies, and the minimum paid-up capital of J$16 million is the same across all classes. We covered the regime end-to-end in “Jamaica’s Proposed VASP Licensing Regime: The Complete Guide.” Here we focus on choosing correctly between the classes.

Class A — Virtual Asset Trading Platform Operator (exchanges)

Class A is for businesses that operate a platform or exchange that brings buyers and sellers together and matches their orders — whether trading virtual assets against fiat currency or against other virtual assets. If your core function is running an order book or matching engine on which third parties trade, you are operating in Class A.

Plain example: a Jamaican crypto exchange where users deposit funds, place buy and sell orders, and trade Bitcoin, Ether and stablecoins against the Jamaican dollar.

Class A carries the heaviest obligations. A trading platform must maintain a documented, board-approved virtual-asset listing (assessment) policy governing which assets it admits and removes; it must operate trade-surveillance systems capable of detecting manipulation in real or near-real time; it must keep order and transaction records for at least seven years; it must offer fair, transparent and non-discriminatory access with published trading rules and fees; and — critically — it is one of the two classes subject to the new quarterly, independently audited proof of reserves. At J$4 million a year, it is also the most expensive class.

Class B — Virtual Asset Advisory Services

Class B is for businesses that advise clients on virtual assets — including investment advice and portfolio management — without necessarily holding client assets or executing trades. If you make recommendations about which virtual assets to buy, sell or hold, you are likely in Class B.

Plain example: a wealth advisory firm or robo-advice app that recommends a virtual-asset allocation to clients based on their goals and risk profile.

The signature requirement for Class B is a documented client suitability framework. Before making any recommendation, the adviser must gather enough information about the client’s financial situation, objectives, knowledge and experience, and risk tolerance to establish that the recommendation is suitable. Where something is unsuitable, the adviser must not proceed — or, if the client insists, must clearly document and disclose that determination first. At J$500,000 a year, Class B is among the lighter-fee classes, reflecting that an adviser who does not hold client assets poses lower prudential risk.

Class C — Virtual Asset Custody Services

Class C is for businesses that safekeep or administer virtual assets — or hold the instruments (such as private keys) that give control over them — on behalf of clients. If clients entrust their assets to you to hold securely, you are in Class C.

Plain example: a digital-asset custodian that holds Bitcoin and Ether in secure storage for institutional clients and pension funds.

Custodians must keep the substantial majority of client assets in cold storage, limit hot-wallet balances to genuine operational needs, insure those hot-wallet holdings, and operate rigorous key-management controls — including multi-signature arrangements and secure key generation, storage, rotation and recovery. Class C is the second class subject to the quarterly proof of reserves, and custodians must also maintain a documented custody transfer or wind-down plan. Notably, the annual fee is just J$400,000 — the lowest of all six classes — even though custody arguably carries significant client-asset risk, a point worth weighing when you model your costs.

Class D — Virtual Asset Broker-Dealer

Class D is for businesses that deal in virtual assets as principal or agent — buying and selling on behalf of clients. If you execute purchases and sales for customers (rather than merely running a venue where they trade with each other), you are in Class D.

Plain example: an over-the-counter (OTC) desk that sources and sells virtual assets directly to clients, or a brokerage that fills client orders against its own book or the market.

The signature requirement for Class D is an appropriateness assessment. Where executing transactions on a non-discretionary basis, the broker-dealer must assess whether the client has sufficient knowledge and experience to understand the risks, and must warn the client where a transaction is inappropriate before proceeding. Importantly, where a Class D firm also exercises discretion over client assets, the fuller Class B suitability obligations apply. The annual fee is J$1,600,000.

Class E — Virtual Asset Wallet Services

Class E is for businesses that provide wallet infrastructure enabling clients to store, manage and transfer virtual assets. If your product is the wallet through which customers hold and move their assets, you are in Class E.

Plain example: a hosted-wallet app that lets users store virtual assets and send and receive them from their phones.

Because wallet providers hold or control client assets, Class E shares the cold-storage and key-management requirements of custody: the substantial majority of assets in cold storage, hot-wallet balances limited and insured, and documented key-generation, storage, rotation and recovery procedures. The annual fee is J$2,400,000 — the second highest of all classes, and notably higher than both custody (Class C) and broker-dealer (Class D), which is a calibration worth factoring into any wallet-led business plan.

Class F — Virtual Asset Conversion Services

Class F is for businesses that facilitate the conversion of one virtual asset into another, or of virtual assets into fiat currency and vice versa, outside of an exchange platform. If your core service is the swap or on/off-ramp itself — not an order-matching venue — you are in Class F.

Plain example: a remittance or on-ramp service that lets customers convert Jamaican dollars into stablecoins (or back) at a quoted rate, without operating an order book.

Conversion services sit at the heart of money-laundering and Travel-Rule risk, because they are where value crosses between the fiat and virtual worlds. Class F therefore emphasises AML/CFT controls — customer due diligence, blockchain analytics, sanctions screening, and the Travel Rule for transfers. The annual fee is J$800,000.

How do I know which class I need?

The decisive question is always functional: what do you actually do for your customers? Use the quick mapping below as a starting point, then confirm against the full definitions and your specific operating model.

If your business…	You likely need…
Runs a venue where customers trade with each other	Class A (Trading Platform)
Recommends or manages virtual-asset investments	Class B (Advisory)
Holds or safekeeps client assets / private keys	Class C (Custody)
Buys and sells assets for clients as principal or agent	Class D (Broker-Dealer)
Provides the wallet customers store and transfer assets in	Class E (Wallet)
Swaps assets or runs an on/off-ramp outside an exchange	Class F (Conversion)

Be careful with overlaps. Many real businesses do more than one of these things — an exchange that also custodies client assets, or a broker that also runs the customer’s wallet. Where you carry on more than one regulated activity, you need a licence for each, as explained next.

What if my business spans more than one class?

Multi-class operators pay for multiple licences A separate licence is required for each class of regulated activity, and each class carries its own annual fee. Consider a vertically integrated exchange that also custodies client assets and provides hosted wallets. It would need Class A, Class C and Class E — an annual fee total of J$4,000,000 + J$400,000 + J$2,400,000 = J$6,800,000, plus the one-off J$800,000 application processing fee, before any compliance build cost.

This matters for two reasons. First, budgeting: the more activities you bundle, the more licences and fees you carry. Second, design: it can sometimes be cleaner to partner for an activity (for example, using a separately licensed custodian) rather than license it yourself — though integration has its own advantages in control and customer experience. The right structure is a strategic decision, best made before you build, not after.

Class-specific obligations at a glance

Beyond the general licensing criteria that apply to everyone — capital, fit and proper, AML/CFT, cybersecurity, governance and substance — each class carries distinctive obligations. The summary below shows which signature requirements attach where.

Requirement	Applies to	What it means
Asset listing policy	Class A	Board-approved policy on admitting and delisting assets, reviewed at least annually
Suitability	Class B (and discretionary D)	Establish that a recommendation fits the client before acting
Appropriateness	Class D	Warn clients when a non-advised transaction may be inappropriate
Cold storage & key management	Classes C and E	Substantial majority in cold storage; insured hot wallets; key controls
Proof of reserves	Classes A and C	Quarterly, independently audited reconciliation of client assets to liabilities

A few real-world scenarios

To make this concrete, here is how several common business models map to the classes:

• A homegrown Jamaican crypto exchange that holds customer balances: Class A (the platform) plus Class C (custody of those balances) — and both trigger proof of reserves.
• A custody-only startup safekeeping assets for institutions: Class C, with cold-storage, key-management and proof-of-reserves obligations.
• A robo-advisory app that recommends allocations but never holds assets: Class B, focused on the suitability framework.
• An OTC trading desk buying and selling for clients: Class D, with appropriateness assessments (and Class B suitability if it manages assets on a discretionary basis).
• A consumer wallet app: Class E, with cold-storage and key-management controls.
• A stablecoin on/off-ramp or remittance service: Class F, with heavy emphasis on AML/CFT and the Travel Rule.

What this means for your application and budget

Choosing your class or classes is the first strategic decision in the licensing journey, because it drives almost everything that follows: which obligations you must build to, which assurance you must commission, and how much you will pay each year. Remember that the J$16 million minimum capital and the core substance requirements — a Jamaican office, a resident director, a locally located Nominated Officer, a local bank account and quarterly board meetings — apply regardless of class, while the annual fees and class-specific obligations stack by activity. A clear-eyed class strategy avoids two costly mistakes: under-scoping (and being told to re-apply or cease an activity) and over-scoping (and paying for licences and controls you do not need).

What to do next

Start by writing down, in plain language, exactly what your business does for customers — then map each activity to a class using the guide above. Stress-test the overlaps, model the stacked fees, and decide consciously what to license and what to partner for. The companion article “VASP Licensing Requirements in Jamaica: The Complete Checklist” then takes you through everything you must assemble to apply.

Frequently asked questions

How many VASP licence classes are there in Jamaica?

Six: Class A (trading platform operator), Class B (advisory services), Class C (custody services), Class D (broker-dealer), Class E (wallet services) and Class F (conversion services).

Do I need more than one VASP licence?

Only if you carry on more than one class of regulated activity. A separate licence is required for each class, and each carries its own annual fee. Many operators need one or two classes; integrated platforms may need three or more.

Which classes have to provide proof of reserves?

Class A (trading platforms) and Class C (custodians). Both must conduct a proof-of-reserves exercise at least quarterly, verified by an independent auditor acceptable to the Commission.

Which classes have cold-storage requirements?

Classes C (custody) and E (wallet services). Both must keep the substantial majority of client assets in cold storage, limit and insure hot-wallet holdings, and maintain robust key-management controls.

How much do the licences cost each year?

Indicative annual fees are: Class A J$4,000,000; Class B J$500,000; Class C J$400,000; Class D J$1,600,000; Class E J$2,400,000; and Class F J$800,000, plus a one-off J$800,000 application processing fee. The J$16 million minimum capital applies to all classes.

How Dawgen Global can help Choosing the wrong class — or missing one — is an expensive mistake. Dawgen Global helps operators scope the right licence or licences before they build and apply: mapping your activities to Classes A through F, modelling the stacked fees and capital, and deciding what to license versus partner for. As an independent professional services firm, we also provide the assurance the regime requires, including proof-of-reserves and client-asset audits for Class A and Class C licensees. We act as adviser and independent auditor to the virtual-asset ecosystem; we are not a licence applicant. To scope your VASP licence strategy, contact us at [email protected] or visit dawgen.global.

This article is part of The Caribbean Virtual Asset Regulation Imperative™ series by Dawgen Global, powered by DAGAF™ — the Dawgen Digital Asset Governance & Assurance Framework. It is general information based on the FSC’s consultation documents of 10 June 2026 and is not legal, regulatory or investment advice. The proposals remain subject to change following consultation.

 

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