Gibraltar: Crypto / Digital Assets / Financial Innovation

Gibraltar's dedicated AML travel-rule instrument for virtual-asset transfers, the Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021, in effect since March 2021, has been revoked by LN.2026/134 effective 15 July 2026. The text of any successor instrument has not been retrieved this cycle, leaving the substantive AML content governing virtual-asset transfer reporting in Gibraltar unconfirmed. From a financial-integrity architecture perspective, this is a notable gap: a jurisdiction with an active and growing virtual-asset licensing ecosystem has, at least temporarily and as far as this cycle's research can confirm, lost its dedicated travel-rule instrument without a visible replacement, creating uncertainty about whether FATF Recommendation 15 obligations for virtual-asset service providers continue to be met through some other mechanism or have a genuine coverage gap.

This sits alongside continued commercial expansion in Gibraltar's tokenisation space. Bullish Group received GFSC approval to trade tokenised securities around late June 2026, and the Protected Cell Companies (Amendment) Act 2026, enacted 9 July 2026, creates a bespoke regime allowing Experienced Investor Funds structured as protected cell companies to issue cell shares as DLT share tokens. Neither of these commercial developments has a confirmed independent GFSC primary-source notice; the Bullish Group finding rests on the company's own announcement, a limitation worth bearing firmly in mind when weighing the strength of that specific claim.

The juxtaposition is analytically significant: a jurisdiction expanding its virtual-asset and tokenisation commercial footprint while simultaneously experiencing an apparent AML-instrument gap in exactly that same sector is the kind of structural mismatch that typically generates elevated illicit-finance risk, independent of any observed enforcement activity. Enablement without confirmed enforcement infrastructure is itself a significant signal in this domain, and the absence of any located enforcement action under the prior travel-rule regime, or any announced replacement, should not be read as an absence of risk.

Outlook

Identifying the successor instrument, if one exists, to the revoked Transfer of Virtual Assets Regulations 2021 is the single most consequential open item in Gibraltar's crypto/digital-asset AML posture. Until that text is located and its substantive content confirmed, Gibraltar's practical compliance with FATF Recommendation 15 for virtual-asset transfers cannot be assessed with confidence. Continued commercial growth in the tokenisation space, absent confirmation of the underlying AML infrastructure, should be read as a widening, not a narrowing, of this gap.