Trinidad and Tobago amends the original two‑year blanket ban on crypto. The strict ban has been significantly softened: the bill has passed with 200+ amendments, introduces a regulatory sandbox, shortens the “freeze” period, and allows existing operators like Guap to keep serving users under supervision rather than shutting down.
Trinidad and Tobago’s Parliament has passed the Virtual Assets and Virtual Asset Service Providers (VASPs) bill, but not before the bitcoin community successfully pushed for over 200 amendments that dramatically softened an initial proposal for a two-year blanket ban.
The bill, which was driven by a tight deadline to achieve compliance with the Financial Action Task Force (FATF) standards by March 2026, passed both the House of Representatives and the Senate in late November 2025.
Alexandra Lutchman, Chief Operating Officer of Guap and a key advocate against the original measure, explained the severity of the initial proposal and the industry’s response. She stated:
“The bill in its original form had a 2-year blanket ban… Anybody owning or selling distributing cryptocurrency including Bitcoin or stable coins was subject to a $5 million Trinidad Tobago dollar fine and jail time… So Guap and key players who are in Trinidad Tobago in the cryptocurrency space said “hell no.” Lack of a better word, hell no. Because this is a tool… It needs to be regulated… But a blanket ban is not going to achieve that. And so we led the charge in getting in the same rooms as the ones who would pass this bill either in its original form or something that could be better in our opinion.”
The advocacy effort resulted in significant changes to the legislation, which passed with a final vote of 25-1. “The bill has over 200 amendments… which were championed by the virtual asset working group which is many players in Trinidad who want to see technology and innovation thrive including Guap,” Lutchman confirmed.
Introduction of the Regulatory Sandbox
The most crucial amendment is the establishment of a Regulatory Sandbox, which allows existing VASPs to continue operating.
Lutchman detailed the function of this new framework:
“The one that I want to highlight now is that there’s a regulatory sandbox. And for those who don’t know what a sandbox is in this context, it is a way for operators such as Guap or other key players to continue operating with certain levels of communication… saying that we are happy to build in a manner that keeps you compliant… So not only do companies still be able to operate, customers can still work, customers can still use crypto, but then finally government can regulate and protect citizens who are at risk.”
The new law also reduced the original two-year freeze on new operators to one year, until 2026. For existing Guap customers, Lutchman confirmed it is currently “business as usual.”
Looking ahead, Lutchman stressed that the industry’s work is not complete. She noted the win is conditional and requires continued collaboration:
“It is a win but the work is not done yet… it’s a win that the government has been open to the sandbox and being ready to accept crypto and Bitcoin in the way that we use it. But it could be superficial, right? After the sandbox is closed, it can be like, well, it’s a little too much effort… or as people have proven time and time again their voices can be heard and that the sandbox can lead to real permanent fair regulations that are long-lasting.”
Key changes in the new bill
- The Virtual Asset and Virtual Asset Service Provider Bill has now passed both the House of Representatives and the Senate in Trinidad and Tobago.
- The original version contemplated a two‑year blanket ban until December 2027 with criminal penalties and multi‑million‑dollar fines for anyone operating or transacting in crypto, including Bitcoin and stablecoins.
- After pushback from Guap and other local crypto players, the government accepted more than 200 amendments, which were introduced and passed with the support of the majority government.
From blanket ban to sandbox
- Instead of a hard blanket ban, there is now a regulatory “sandbox” that lets current virtual asset service providers continue operating if they qualify and work closely with regulators.
- The freeze now mainly applies to new operators or anyone trying to operate outside the sandbox, rather than shutting down firms already serving users.
Timing and FATF pressure
- The rush is driven by Trinidad and Tobago’s need to stay compliant with the Financial Action Task Force (FATF) standards and avoid returning to the FATF grey list, with a key review deadline around March 2026.
- FATF compliance is framed as essential for continued access to international markets, trade, and correspondent banking, not just for crypto regulation.
Practical impact for users and Guap
- For Guap customers, the short‑term message is “business as usual”: existing services can keep running while Guap operates inside the sandbox and co‑develops detailed rules with regulators.
- There is still a freeze period (now shortened to 2026 instead of 2027) that affects market entry for new providers, and there is a risk that, if the sandbox remains only “on paper,” the government could revert to something closer to a ban after the sandbox window closes.
Individuals, ownership, and KYC direction
- Individual ownership of Bitcoin and other crypto remains possible; what is restricted and regulated is the business of providing virtual asset services (buy/sell/transfer as a service), especially outside approved channels.
- The future KYC/AML setup is not yet fully defined, but the direction discussed is a tiered approach: small, daily cash-based purchases with little or no KYC, and progressively stronger KYC as amounts and risk levels increase, particularly to combat fraud and scams like romance scam
