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Ready for CIMA before CIMA asks.

Virtual asset service providers must prove to CIMA that their technology, cybersecurity and outsourcing are sound. GABCO Enterprises measures your arrangements against CIMA requirements, closes the gaps and keeps your evidence inspection ready.

Overview

What is included

  • Readiness gap review against CIMA rules and guidance
  • Cybersecurity programme design and documentation
  • Continuity and recovery plans, written and tested
  • Incident response planning and tabletop exercises
  • Oversight of cloud and outsourced providers
  • Technology sections of registration and licence applications
  • Mock inspections and evidence preparation
  • Ongoing compliance monitoring and annual reviews

The Cayman Islands has a comprehensive framework for virtual asset businesses. Under the Virtual Asset (Service Providers) Act, VASPs must register with or be licensed by the Cayman Islands Monetary Authority, and CIMA expects sound governance, controls and operational resilience before and after authorisation.

Technology is at the heart of that expectation. Custody arrangements, trading systems, wallet infrastructure, cloud providers and outsourced services all shape a VASP's risk profile. CIMA's Rule and Statement of Guidance on Cybersecurity for Regulated Entities apply, alongside expectations on continuity, outsourcing and incident response.

GABCO Enterprises prepares the technology and resilience side of your regulatory position. We find the gaps, build the controls and documentation, prove they work and keep the evidence CIMA expects to see.

Who it is for. VASPs registered or licensed with CIMA: trading platforms, custodians, exchanges and token issuers, plus funds and service providers with virtual asset exposure. We work alongside your legal counsel and compliance team.

  • Virtual Asset (Service Providers) Act
  • CIMA Rule on Cybersecurity
  • CIMA Statement of Guidance
  • ISO/IEC 27001
  • NIST CSF 2.0
  • ISO 22301
Field notes

What most firms don't know about VASP Readiness

Facts and practices that rarely make it into a proposal, but decide how well the work holds up.

72hours

Incident notice applies to VASPs too

As CIMA regulated entities, VASPs must notify CIMA immediately, and within 72 hours, of a material cybersecurity incident. Inspectors ask to see the plan that makes this possible.

Source: CIMA Rule on Cybersecurity for Regulated Entities

Apr2025

Custodians and trading platforms need a licence

Since April 2025, virtual asset custodians and trading platforms in Cayman have needed a CIMA licence, not only registration. The technology bar rises with it.

Source: Virtual Asset (Service Providers) Act

Keyscontrol

Whoever controls the keys controls the assets

Key generation, storage, backup and who can sign are the first things an inspector asks about. Written key ceremonies and quorum signing turn that answer into evidence.

GABCO field practice

Cloudis outsourcing

A cloud provider is an outsourcing arrangement

Hosting wallets, exchanges or records with a cloud provider is outsourcing in CIMA's eyes. Due diligence, exit plans and access to data must be documented before inspection.

Source: CIMA outsourcing guidance

Discuss VASP Readiness with us

Tell us what you're working on. We'll listen, ask the right questions and recommend a practical next step. No obligation.

info@gabcoenterprises.com+1 345 769 4222