Companies licensed under the Digital Assets and Registered Exchanges (DARE) Act, 2024 in The Bahamas are subject to a comprehensive set of compliance requirements. These obligations cover both the initial registration process and ongoing operational standards, ensuring businesses remain aligned with international best practices, especially in areas of AML/CFT, risk management, and corporate governance.

This checklist is designed to help licensed entities or applicants maintain full compliance under the DARE framework.

1. Registration Phase
   
   

Corporate Setup

• Register as an International Business Company (IBC)
• Appoint a Bahamian registered agent and maintain a local registered office
  
  

Application Forms & Key Individuals

• Submit Form 1 – Business registration application
• Submit Form 2 – Personal questionnaire for each director, beneficial owner, and officer
• Submit Form 3 – CEO and Compliance Officer registration
• Ensure all key individuals meet the “fit and proper” standards required by the SCB
  
  

Required Documentation

• Business plan detailing services, revenue model, and financial projections
• AML/CFT compliance policies and procedures
• Cybersecurity and data protection framework
• Internal controls and risk management systems
• Audited financial statements or financial projections (if newly established)
• Organizational chart with job descriptions
• Evidence of regulatory capital and, if applicable, insurance coverage
• Schedule of proposed service fees
  
  

1. Ongoing Compliance Obligations
   
   

Corporate Governance

• Maintain a registered office and agent in The Bahamas
• Notify the Securities Commission of The Bahamas (SCB) of any material changes in ownership, management, or business operations
• Renew registration annually and pay applicable renewal fees
  
  

Financial Reporting

• Submit annual audited financial statements to the SCB
• Provide interim financial reports upon request
  
  

AML/CFT and Risk Management

• Maintain up-to-date AML/CFT policies and procedures
• Conduct regular internal risk assessments
• Perform customer due diligence (CDD) and enhanced due diligence (EDD) when required
  
  

Personnel Requirements

• Ensure CEO and Compliance Officer remain active and approved
• Notify the SCB promptly of any changes to key personnel
  
  

Operational Policies

• Keep cybersecurity, internal control, and IT systems regularly updated
• Monitor transactions and maintain accurate records of business activities
• Retain client and transactional data in compliance with SCB guidelines
  
  

Regulatory Cooperation

• Prepare for and cooperate with periodic inspections and audits by the SCB
• Respond promptly to any regulatory inquiries or information requests
  
  

Best Practices

• Conduct quarterly internal compliance audits
• Consider third-party compliance or legal advisors for support
• Maintain detailed records of all compliance procedures, updates, and correspondence
  
  

Adhering to this checklist helps ensure that your digital asset business remains compliant, secure, and reputable under the DARE regulatory framework in The Bahamas.