1. Introduction
Sunshine is a Trinidad and Tobago-based Stablecoin Exchange, Remittance Service and Financial Technology company, founded in 2022 by local Trinbagonian entrepreneur, Jarryon Paul. Our mission is to Empower our Members with the Products, Services, Education & Experiences that make Financial Freedom possible. We serve approximately 2,500 Trinbagonian customers and have operated from inception with full Know Your Customer (KYC), Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) and transaction monitoring protocols, mirroring the standards of traditional financial institutions. Now, we are in the process of upgrading our AML/CFT policies to be fully compliant with the Financial Action Task Force (FATF).
We welcome the government’s initiative to regulate the Virtual Asset industry via the Virtual Assets and Virtual Assets Service Providers Bill, 2025 (VAVASPB). Effective regulation is crucial for consumer protection, market integrity, national economic growth and international compliance.
However, in its current form, the Bill does not regulate—it terminates. It will force the immediate shutdown of legitimate, compliant domestic operators, harming consumers and stifling innovation, while inadvertently empowering illicit actors, and still not necessarily meet FATF’s standards.
This paper outlines our core concerns and proposes pragmatic amendments to transform the VAVASPB into a world-class regulatory framework that protects citizens, meets international compliance standards and allows the digital assets industry to thrive in Trinidad and Tobago.
2. Executive Summary of Concerns
The VAVASPB, as drafted, presents a critical threat to the legitimate digital asset industry and financial innovation in Trinidad and Tobago due to one primary provision:
- Clause 4(3) & (5): A De Facto Ban: The Bill imposes a moratorium on licensing until the end of 2027 and mandates that all existing operators (Clause 4(5)) must cease all activities within three months of enactment. This is not a regulatory pause but an outright prohibition that will:
- Eliminate Consumer Choice: Shut down safe, regulated on-ramps and off-ramps for citizens wishing to utilize digital assets for remittances, savings or investments.
- Cede the Market to Bad Actors: Non-compliant and offshore entities operating without oversight will continue to serve market demand, but now without any local, regulated competition. This pushes activity underground and increases, rather than decreases, consumer risk.
- Stifle Economic Growth: It halts investment, eliminates jobs in a nascent and growing tech sector and contradicts the National Vision for innovation exemplified by the establishment of the Ministry of Public Administration and Artificial Intelligence.
- Penalise Compliance: Companies like Sunshine, which have proactively implemented robust compliance frameworks, are punished equally alongside the very actors the Bill seeks to control.
3. The Path Forward: Principles for Effective Regulation
We believe Trinidad and Tobago can and must do better. Global precedents from the USA’s GENIUS Act (2025), EU’s MiCA Regulation (2023), Bermuda’s DABA (2018), and The Bahamas’ DARE Act (2020) demonstrate that a balance between innovation and consumer protection is not only possible but already operational.
A responsible Bill should be built on four core principles:
1.Immediate Consumer Protection: Regulations must empower the regulator to enforce internationally accepted KYC, AML/CFT, and financial reporting standards immediately.
2. Inclusion of Existing Operators: Legitimate existing businesses must be brought into a regulated framework, not excluded by a moratorium.
3. Pro-Growth and Pro-Innovation: Regulation should provide legal certainty to encourage responsible investment and job creation in the digital economy.
4. FATF Guideline Compliance: Regulations should be FATF compliant and consistent with this international standard.
