International banking, trust services, insurance, payments, securities and gaming each raise distinct questions about authorisation, capital, governance and continuing supervision.
We help prospective applicants organise their business information and identify the specialist advice required for an initial assessment.
International banking
International banking is governed by the International Banking Act 2016, as amended, and supervised by the FSRC. The licence classes distinguish general international banking, banking for a restricted customer list and composite international banking and trust business.
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These are published minimums. The FSRC may determine a higher requirement and must approve the applicable arrangements. A proposal must also address management, local operations, risk controls and the ability to meet continuing supervisory obligations.
International trust business
The FSRC distinguishes a Class I General International Trust Licence from a Class II Restricted International Trust Licence. Its published requirements state a minimum of US$250,000 in paid-up capital for a Class I licence, subject to the Commission's determination.
Trust business requires suitable personnel and a physical presence, with records and procedures available for regulatory examination. Advice should address both the provider's authorisation and the legal arrangements it intends to administer.
International insurance
International insurance business requires the appropriate FSRC licence and compliance with the conditions attached to it. The FSRC publishes a minimum paid-up capital requirement of US$250,000, alongside fees and application requirements.
The proposed insurance activities, ownership, financial resources and operating arrangements need individual review. An indicative formation period should not be taken as a guaranteed authorisation date.
Money services and payments
Money transmission, currency exchange and payment services require careful classification. The review should address the Money Services Business Act 2011 and the Payment Systems and Services Act 2025, which provides for ECCB licensing and oversight of payment services and systems.
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Confirm commencement, transitional arrangements and the responsible authority for the proposed activity before filing. An application should identify the precise services, customer groups and transaction channels involved. Systems for customer verification, transaction monitoring and reporting should be considered at the design stage, particularly where a service will operate through agents or digital channels.
Investment funds and securities
An investment fund or securities business may engage the regional framework administered by the Eastern Caribbean Securities Regulatory Commission. The classification of a fund, its proposed investors and the role of its manager and other service providers determine the permissions to be considered.
Obtain advice on the applicable law, commencement provisions and any transitional arrangements before launching or promoting a fund. A general company registration or an unrelated financial licence does not resolve those questions.
Interactive gaming and wagering
The FSRC's Division of Gaming oversees the offshore gaming sector. Applicants should address the relevant gaming permissions, ownership and management standards, player protection and financial controls.
Operators must also assess the laws of the markets they intend to serve. A licence in Antigua and Barbuda does not override restrictions imposed by another jurisdiction.
Digital assets
Businesses involving digital assets should review the separate digital assets business framework and consider whether their activities also engage banking, payment or securities requirements. The correct approach follows the service being provided rather than the label given to the technology.
Financial crime controls
A regulated business must plan for customer due diligence, verification of beneficial ownership, transaction monitoring, record retention and reporting under the applicable financial crime laws.
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Licensing is accompanied by continuing duties to prevent money laundering and the financing of terrorism and proliferation. The Office of National Drug and Money Laundering Control Policy, or ONDCP, performs financial compliance and intelligence functions. Its Financial Intelligence Unit receives and analyses suspicious activity reports. These responsibilities should be considered alongside supervision by the relevant licensing authority.
Prepare for an initial assessment
Provide a business summary, proposed ownership structure, funding plan and intended markets. We can help direct the enquiry and identify the specialist advice required.