The Financial Services Commission (Digital Asset Services Licensing) Regulations, 2025 (the “Regulations”), which came into force on 30 December 2025, establish a comprehensive legal framework to regulate digital asset services and mitigate potential risks such as money laundering, terrorist financing, and proliferation financing.

Who falls within the scope of the Regulations?
The new regulations apply to all persons or entities that carry on, or hold themselves out as carrying on, digital asset services in or from within Belize. Accordingly, they will be required to be licensed. In addition, any entity incorporated or registered under the laws of Belize that provides digital asset services outside Belize is deemed to be providing such services from within Belize.

What activities are considered digital assets services under the Regulations?
The Regulations prescribe the following activities as digital asset services requiring a licence:
• Exchange between digital assets and fiat currencies.
• Exchange between one or more forms of digital assets.
• Transfer of digital assets.
• Loan, deposit, custody, safekeeping, management, or administration of digital assets or instruments enabling control over digital assets.
• Participation in and provision of financial services related to the issuance, offer, or sale of a digital asset.

What are the licensing criteria and obligations?
The Regulations establish several licensing criteria. In assessing an application, the Commission considers the nature of the proposed activities, the applicant’s risk profile, and whether the applicant and its relevant persons are fit and proper.

Licensed persons must implement robust AML/CFT controls, manage operational and cybersecurity risks, and promptly report any material incidents to the Commission.
Licences may also be granted subject to any conditions, limitations, or restrictions that the Commission considers appropriate.

What activities are exempted from these Regulations?
Persons providing purely ancillary technical, software, infrastructure, or support services are excluded only where they do not take custody of digital assets, exercise control over digital assets, or otherwise deal in digital assets on behalf of another person. However, the Commission may determine that such persons fall within scope where their activities give rise to material regulatory, consumer protection, or financial crime risks.

Please note that the Regulations will expire when the Financial Services Commission (Amendment) Act, 2026 comes into force. Existing licences under the Regulations will remain valid until their expiry unless varied, suspended, or revoked, and any pending applications will be determined under the law in force at the time of determination.
Please note that the information provided is a general overview and not intended as legal advice. For further assistance or clarification, feel free to contact our team at quijano@quijano.com