KEY TAKEAWAYS
As the digital assets sector matures, jurisdictional choice is no longer about speed or simplicity. Institutional clients are increasingly making strategic, long-term decisions about where to domicile their businesses by balancing regulatory clarity, reputational strength and commercial viability.
Racing to market via the quickest route has given way to clients focusing on future-proofing their structures in a highly scrutinised and frenetic global environment.
A clear shift is underway. Clients are engaging in ‘global regulatory hopscotch’, weighing the pros and cons of each jurisdiction's product classification rules, licensing thresholds, enforcement trends and cross-border compatibility.
The goal isn’t just to get licensed: it’s to build credibility. Here are some of the trends our fintech team has picked up on in 2025 and beyond.
Each international investment hub offers something different, and clients are starting to treat them accordingly. The Cayman Islands remains a popular choice for flexible structuring and fast market entry, particularly for foundation companies and investment funds. A recent April 2025 proposed amendment to the VASP Act clarified that tokenised funds are no longer caught by the regime, giving institutional clients clearer structuring options and removing regulatory ambiguity in this area.
The British Virgin Islands (BVI), meanwhile, continues to attract token issuers. The jurisdiction offers simplicity and cost-efficiency, especially for early-stage projects.
Bermuda has carved out a stronghold for clients seeking a prudent and well respected regulatory engagement with a reputation for fostering innovation. Its risk-based, tiered approach allows businesses conducting digital assets business activities (DAB) to start with a sandbox licence and graduate to a full DAB licence as they scale meaning that there is an option for everyone from start-ups and those testing novel business models to global digital finance companies and exchanges. For many institutional players, Bermuda’s proactive and risk-based regulator and established financial services reputation offer a 'gold stamp' of credibility. The clear guidance to DABs on single currency pegged stablecoins and custody demonstrates the Bermuda Monetary Authority’s collaborative approach to licensing.
Jersey is gaining traction as a tokenisation hub, particularly for real-world assets. Clients see its regulator’s thorough review process as a value-add: regulatory sign-off is viewed not as red tape, but as quality assurance. The island’s detailed guidance on how tokenised products fit under existing law is also helping clients navigate complex classification challenges. While elsewhere in the Channel Islands, Guernsey has led the way with respect to trust structures for digital assets.
While newer jurisdictions are entering the spotlight, established international financial centres like Bermuda, BVI, the Cayman Islands and the Channel Islands remain central to institutional digital asset strategies. Rather than being replaced, these jurisdictions are increasingly part of a complementary global structuring approach, where clients align different vehicles, licences and regulatory positions across borders to support international scalability.
Abu Dhabi and Dubai are emerging as innovation hubs with supportive government initiatives and rapid licensing timelines, while interest in the US is reawakening at a rapid pace under the current administration. Notwithstanding this, clients continue to weigh the long-term implications of regulatory uncertainty in key onshore markets.
Meanwhile, the EU’s MiCA framework is shaping strategy for Europe-bound products. Ireland is becoming a common access point for clients targeting the single market, especially for altcoins and tokenised securities.
Against this backdrop, clients are relying on trusted investment hubs to anchor their structures with regulatory clarity and global interoperability. The ability to combine innovation in newer jurisdictions with credibility and experience in places like Bermuda, BVI, Cayman, the Channel Islands and Ireland remains a key advantage for institutional players building long-term, cross-border growth. The increasing tendency towards a global strategy is recognised by regulators, such as the joint memorandum understanding signed in 2024, between the Financial Services Regulatory Authority of the ADGM signaling the path forward for collaboration on regulatory oversight and licensing.
What’s clear is that clients are no longer looking for a one-size-fits-all solution. The trend is towards specialisation: Cayman for foundation companies, BVI for token issuers, Bermuda for innovative digital assets businesses, stablecoin issuers and regulated institutional players, Jersey for tokenised assets, Guernsey for digital assets trusts and Ireland for MiCA entry. This shift demands legal advisors who can think globally and act locally to help clients build regulatory resilience from day one.
See what's ahead and how to prepare in the digital assets landscape. Our full fintech white paper, ‘Digital assets in the post-boom world: Building infrastructure, not hype’, dives into how businesses can scale and build credibility in an uncertain market.
Partner/Cayman Islands
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