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Brunei’s Approach to Virtual Assets: What Fintech Firms Should Prepare For 

If you’re a fintech company eyeing Brunei’s emerging market, here’s what you should know about virtual assets. Regulation around financial services in Brunei is still developing, which means that there are both opportunities as a fresh market and also challenges associated with it. The nation’s central bank hasn’t made any rash decisions, though. Instead, they’re adopting a methodical, measured strategy that puts consumer protection first while allowing for innovation and also compliance with their Islamic identity. 

Although Brunei may not immediately spring to mind when considering crypto hubs, it would be incorrect to ignore it. The Autoriti Monetari Brunei Darussalam (AMBD, also known as BDCB) has been discreetly developing a framework that may make Brunei’s cryptocurrency regulation one of Southeast Asia’s most deliberate and well thought-out.  

The Current Scenario: Where Brunei Stands on Crypto? 

Let’s get the basics out of the way first. As of now, cryptocurrencies aren’t legal tender in Brunei. They’re not regulated as currency, and BDCB has made it clear: they don’t oversee crypto assets the way they oversee traditional financial instruments. 

But here’s the thing; that doesn’t mean virtual assets of the Brunei operations exist in a complete regulatory vacuum. While cryptocurrencies themselves aren’t directly regulated, any activities surrounding them that touch regulated financial services definitely are. If you consider deposit-taking services, extending loans, facilitating cross-border remittances, providing foreign exchange services, or issuing securities (all while involving crypto), it becomes necessary to comply with existing financial regulations. 

The situation gets even more interesting when you look at what’s happening behind the scenes. BDCB has been openly acknowledging the “rapid growth of cryptocurrencies globally” and the “heightened interest from the public.” Their response? “An appropriate legal and regulatory framework for the licensing and supervision of cryptocurrencies and related activities” is presently being developed. Being ready is preferable to being unprepared for the impending change. After company formation in Brunei, if you are looking to establish your business in the fintech sector, you must have a fair idea of Brunei’s approach to virtual assets.  

What’s Not Covered (Yet)? 

Crypto mining occupies its own grey zone in Brunei. The activity of using computers or specialized machines for mining falls outside BDCB’s regulatory scope, at least for now. But don’t mistake that for a free pass. Given the enormous amount of electricity needed for these operations, BDCB has stated that it will collaborate with other government agencies on any issues pertaining to cryptocurrency mining. 

As of 2025, mining cryptocurrencies is neither expressly prohibited nor supported by official laws in Brunei. Since you’re essentially in unfamiliar territory, any operations you establish may be subject to future regulatory changes. 

The VASP Framework in Brunei: What’s on the Horizon? 

Here’s where things get particularly interesting for fintech firms. So, what’s Brunei actually doing here? They’re working to set up VASP (Virtual Asset Service Provider) licensing for companies dealing in virtual assets. What qualifies as a virtual asset? 

Here’s what the Financial Action Task Force (FATF) defines a virtual asset as:  

‘A digital representation of value that can be digitally traded or transferred and used for payment or investment purposes.’ 

Essentially, VASPs are the businesses that make the crypto ecosystem tick. We’re talking exchanges, wallet providers, token issuers, things like that.​ 

Now, Brunei isn’t just throwing something together and hoping it works out. They’re committed to implementing FATF standards across the board. Brunei’s financial proactiveness can be seen from its active membership in the Asia/Pacific Group on Money Laundering (APG).  

In November 2022, the nation even underwent a thorough Mutual Evaluation by the APG, which was essentially an assessment of how well it adheres to international anti-money laundering and counter-terrorism financing (AML/CFT) standards.  

And here’s the kicker: during their 28th National Anti-Money Laundering Council meeting, they endorsed a 2021 Virtual Asset risk assessment. It explains that virtual asset regulation isn’t just talk; it’s clearly on the agenda and being taken seriously. 

What the VASP Brunei Framework will Likely Cover? 

Based on BDCB’s public statements, here’s what fintech firms should expect when Brunei’s crypto regulation for VASPs comes into full effect: 

Licensing Requirements 

• Registration and incorporation of the business in Brunei 

• Comprehensive business plans demonstrating viability and benefits 

• Proof of adequate capital reserves 

• Fit and proper assessments for directors and key personnel 

• Clear governance and organizational structures 

Operational Standards 

• Robust cybersecurity measures and data protection  

• Customer complaint handling procedures 

• Regular reporting to BDCB on operations and financials 

• Technology infrastructure that meets regulatory standards 

• Business continuity planning and disaster funds 

Consumer Protection Measures 

• Transparent fee structures and disclosure requirements 

• Client asset segregation from company funds 

• Clear terms of service and user agreements 

• Education initiatives for customers about risks 

• Proper handling of customer disputes 

The VASP Brunei framework won’t exist in isolation. It’ll be integrated with Brunei’s existing financial services regulations, creating a comprehensive approach that treats virtual assets as a distinct but connected part of the financial ecosystem. 

Brunei Crypto Regulation and AML Compliance 

If there’s one area where Brunei won’t compromise, it’s AML (Anti-Money Laundering) compliance. The country takes its international obligations seriously, and the framework governing virtual assets in Brunei operations will definitely reflect that commitment. 

The amendments to the Money Changing and Remittance Business Act already introduced provisions requiring oversight of virtual assets. This isn’t some distant future concern it’s happening now. BDCB laying out the groundwork, and fintech firms need to be ready. 

Core AML/CFT Requirements for VASPs 

Here’s what you’ll need to have in place before you even think about applying for a VASP Brunei framework license: 

Requirement Category	What You Need	Why It Matters
Customer Due Diligence	Identity verification systems (KYC), risk assessment protocols, and enhanced diligence for high-risk customers	Ensures you know who you’re doing business with and can detect suspicious patterns
Transaction Monitoring	Real-time monitoring systems, threshold alerts, and pattern recognition capabilities	Catches unusual activity before it becomes a regulatory problem
Record Keeping	At least 5 years of transaction records, customer identification data, and correspondence archives	Regulatory requirements and essential for investigations
Suspicious Activity Reporting	Clear protocols for identifying and reporting suspicious transactions, and designated compliance officers	Legal obligation under AML/CFT laws
Employee Training	Regular AML/CFT training programs, updated procedures, and competency assessments	Your staff is your first line of defense

The BDCB Financial Intelligence Unit (FIU) is the main point of contact for AML matters. They’re responsible for receiving, analyzing, and distributing financial intelligence related to suspected money laundering and terrorism financing. If you’re operating under the VASP Brunei framework, you’ll be reporting directly to them. 

The Travel Rule and Cross-Border Transactions 

One aspect of Brunei crypto regulation that’s particularly important: the Travel Rule. FATF requires that VASPs obtain, hold, and transmit required originator and beneficiary information for virtual asset transfers. This means: 

• For transfers exceeding a certain threshold (typically USD/EUR 1,000), you need to collect and share customer information 

• Both the originating VASP and the beneficiary VASP must exchange this data 

• The information must travel with the transaction 

• You need systems capable of handling this data exchange securely 

This isn’t just a technical requirement. It’s a fundamental shift in how virtual asset transactions work, and implementing it properly requires significant infrastructure investment. 

What Makes Brunei Different: The Regulatory Philosophy? 

So, what sets the virtual assets regulation apart from other jurisdictions? A few things stand out. 

Measured Implementation Over Speed 

Brunei isn’t racing to become the next crypto hub. In order to draw in as many businesses as possible, they are not providing tax breaks or simplified licensing. Rather, consumer protection and sustainability are top priorities in the construction of the VASP Brunei framework. 

There are benefits and drawbacks to this strategy. The biggest pro is that there is less of a chance that regulations will be enforced abruptly without proper structures. When the rules are finalized, they will have been carefully thought out. 

On the flip side, you might wait longer for clarity than you would in more growth-aggressive jurisdictions. 

Integration With Existing Financial Services 

Rather than treating virtual assets as completely separate from traditional finance, Brunei’s crypto regulation integrates them into the existing regulatory architecture. If your virtual asset activities touch on regulated financial services, you’re already subject to oversight. 

This means you can’t only focus on your compliance efforts. Your VASP operations need to align with broader financial services regulations, from data protection to consumer lending rules. 

Alignment With Islamic Finance Principles 

While not explicitly stated in most regulatory documents, Brunei’s status as an Islamic sultanate influences its approach. Virtual assets regulation will need to consider Shariah compliance for any products targeting Muslim consumers. 

This does not imply that all cryptocurrency activities must adhere to Shariah, but knowing the fundamentals of Islamic finance will give you a competitive edge if you are developing products for the local market. Product design should be influenced by ideas such as avoiding interest (riba), excessive uncertainty (gharar), and gambling (maysir). 

The Fintech Sandbox: Testing Ground for Innovation 

One bright spot for fintech firms: Brunei’s FinTech Regulatory Sandbox. This program allows companies to test innovative products and services (even fintech) in a controlled environment with regulatory oversight but reduced compliance burdens. Think of it as an official incubator. 

The sandbox operates under clear guidelines that BDCB updated last in 2024. Here’s what you need to know: 

Eligibility Criteria 

To participate in the sandbox and test virtual assets of Brunei products, you need to meet several criteria: 

• Your product or service must be genuinely innovative or significantly better than existing offerings 

• It should provide identifiable benefits to consumers or the industry 

• You must demonstrate that testing in the sandbox is genuinely necessary 

• Your firm must have adequate capital resources and competent personnel 

• You need a clear testing plan with defined parameters and success metrics 

What the Sandbox Offers? 

• Reduced Regulatory Requirements: Not a free pass, but certain requirements may be relaxed during the testing period. 

• Direct Regulatory Engagement: You’ll work closely with BDCB throughout the testing period, getting feedback and guidance. 

• Limited Market Access: You can test with real customers, but within defined limits on transaction volumes, amounts, and participant numbers. 

• Clear Exit Path: Whether you succeed or fail, there’s a clear process for either moving to full licensing or winding down operations. 

For firms developing VASP Brunei framework products, the sandbox offers a valuable opportunity to refine your offering before facing full regulatory scrutiny. It’s not compulsory but it is a great way to check whether your product idea is compliant or not.  

Preparing Your Firm: Practical Steps 

Alright, enough theory. What should you actually do if you’re planning to operate under the VASP Brunei framework once it’s finalized? 

Start With a Compliance Gap Analysis 

Compare your current operations against what you know about emerging Brunei crypto regulation requirements: 

• Do you have robust KYC/AML systems in place? 

• Can you implement the Travel Rule for cross-border transactions? 

• Is your customer data protection up to Brunei’s standards? 

• Do your directors and key personnel meet fit and proper criteria? 

• Can you segregate customer assets properly? 

Where you find gaps, start building solutions now. Don’t wait for the final regulations. 

Build Relationships with Local Partners 

Virtual assets Brunei operations will benefit enormously from local knowledge and connections. Consider: 

• Local legal counsel specializing in financial services 

• Compliance consultants familiar with BDCB’s expectations 

• Banking partners willing to serve virtual asset businesses 

• Technology providers with regional experience 

These relationships take time to develop. Starting early gives you a significant advantage. 

Engage With BDCB Early 

Don’t wait until you’re ready to apply for a license to introduce yourself to regulators. BDCB has shown willingness to engage with industry participants through: 

• Industry workshops and consultations 

• Fintech working groups 

• Direct outreach for firms with serious market entry plans 

Early engagement helps you understand regulatory expectations and shows BDCB that you’re committed to compliance. 

Invest in Technology Infrastructure 

The VASP Brunei framework will have significant technology requirements: 

Compliance Systems 

• KYC/AML platforms with Brunei-specific configurations 

• Transaction monitoring with customizable rules 

• Reporting systems that can interface with BDCB requirements 

Security Infrastructure 

• Multi-layered cybersecurity protects customer assets 

• Cold storage solutions for digital assets 

• Disaster recovery and business continuity systems 

Customer-Facing Technology 

• User-friendly interfaces that still meet compliance needs 

• Clear disclosures and risk warnings 

• Secure communication channels 

Don’t cut corners here. Regulatory technology debt is expensive to fix later. 

Develop Your Compliance Team 

Technology alone won’t make you compliant. You need people who understand Brunei crypto regulation and can implement it effectively: 

• Money Laundering Reporting Officer (MLRO) with VASP experience 

• Compliance officers familiar with FATF standards 

• Legal counsel with Brunei financial services expertise 

• Risk management professionals 

• Internal audit capabilities 

If you can’t hire full-time specialists immediately, consider consultants or shared resources. But have a plan for building internal capacity. 

Timeline Expectations: When Will Things Crystallize? 

Here’s the frustrating truth: we don’t have exact dates for when the full VASP Brunei framework will be operational. What we know: 

• BDCB conducted a Virtual Assets Workshop in early 2024, indicating active development 

• The 2021 Virtual Asset risk assessment was endorsed by Brunei’s AML Council, suggesting that groundwork has been laid 

• Amendments to the Money Changing and Remittance Business Act already reference virtual assets, indicating legislative preparation. 

• International commitments (APG, FATF) create pressure for timely implementation. 

Based on these signals, expect meaningful developments throughout 2025 and 2026. That doesn’t mean waiting passively. The firms that succeed will be those preparing now for regulations that are still being finalized. 

The Opportunity in Uncertainty 

Look, uncertainty is uncomfortable. You’d probably prefer a fully detailed regulatory framework you could simply comply with. But the current state of virtual assets regulation actually creates opportunities for firms willing to engage constructively. 

• Shape the Conversation: Regulators often welcome industry input during development phases. Your expertise could influence how Brunei’s crypto regulation ultimately looks. 

• First-Mover Advantage: Firms that secure early VASP Brunei framework licenses will have established operations before competition intensifies. 

• Relationship Building: The regulatory relationships you build now will serve you for years as you navigate compliance challenges. 

• Market Understanding: Time spent preparing isn’t wasted. You’re developing deep knowledge of Brunei’s market, culture, and regulatory philosophy that will inform everything you do. 

Looking Ahead: Where Virtual Assets Brunei Is Headed 

Brunei’s approach to crypto won’t look like Singapore’s or Dubai’s. It’ll reflect the country’s particular circumstances, priorities, and values. That means: 

• Consumer protection will trump innovation for innovation’s sake 

• International standards (particularly FATF recommendations) will be non-negotiable 

• Integration with existing financial services regulation rather than parallel systems 

• Measured implementation with thorough consideration of risks 

• Strong AML/CFT requirements are given regional concerns about financial crime 

For fintech firms, this creates a market that rewards preparation, compliance, and patient capital over quick wins and regulatory arbitrage. 

The VASP Brunei framework, when it arrives, won’t be the most permissive or the fastest to navigate. But it will offer something valuable: a stable, predictable regulatory environment aligned with international standards. In an industry that’s seen its share of regulatory whiplash elsewhere, that stability has real value. 

To Wrap Up 

Virtual assets regulation is evolving right now, and the VASP Brunei framework is taking shape even as you read this. Brunei’s crypto regulation won’t look like what you’d find in crypto-friendly jurisdictions racing to attract firms with minimal oversight. It also won’t look like the restrictive approaches some countries have taken to shut down innovation entirely. 

Brunei is charting a middle path: welcoming financial innovation while insisting on strong consumer protections and AML compliance. For firms willing to meet those standards, there’s a real opportunity to establish operations in a growing market with strong fundamentals. 

The key is preparing now, not waiting for perfect clarity. Build your compliance infrastructure, develop local relationships, and engage with regulators. Understand the market, when the VASP Brunei framework becomes fully operational, you’ll be ready to hit the ground running while others are still figuring out the basics. 

So, get started. The firms that thrive under virtual assets regulation will be those that saw it coming and prepared accordingly. To get assistance in virtual assets consulting and licensing in Brunei, talk to our experts at Enterslice.  

All You Need To About Brunei Virtual Asset Regulations