Dominica Offshore Banks: One Licence, Four Products

A Dominican offshore bank is a narrow instrument with a clear design: a licence for international business with non-residents, a multi-currency account free of exchange control and local tax, and, since 2022, a separate regime for virtual-asset operations sitting alongside it. That combination turned a small island jurisdiction into a visible niche for banks that keep fiat and crypto in one client cabinet: EQIBank, The Kingdom Bank, Nodabank and the youngest of them, Sentenor Bank.

All four operate under the same statute, and none of them has what a reader instinctively expects from the word "bank": deposit insurance, an ombudsman, a lender of last resort. They differ in product, in the price of a payment, in passport policy, and in how much each bank discloses about itself. What follows is the regime first, then the banks, then what such an account is actually opened for and where it is weak.

Concept

A Dominican offshore bank is a licensee under the Offshore Banking Act 1996 (Act No. 8 of 1996; Chapter 73:02 in the revised laws), supervised by the Financial Services Unit (FSU) of the Ministry of Finance. The licence permits international banking business with non-resident personal and corporate clients and, as a general rule, closes the door to citizens and residents of Dominica. The construction runs parallel to the domestic banking system: the island's ordinary banks live inside the Eastern Caribbean Currency Union under the ECCB, while offshore licensees answer to the national regulator and sit outside the currency union.

The regime's product freedom follows from that. In the wording of EQIBank's licence page, accounts "are not subject to local taxes or exchange restrictions and funds in foreign currencies are transferred freely with no conversion to East Caribbean Dollar required". The bank chooses its own currencies, correspondents and products; what the statute prescribes is not a product range but the boundaries of soundness.

What the statute requires of a licensee

The text of the Act defines offshore banking business as banking business conducted exclusively in currencies other than the East Caribbean dollar, and requires on commencement USD 1 million of issued capital paid up in cash and documented as freely available in liquid form, and thereafter no less than that same figure counting reserves of accumulated profits against accumulated losses.

From its second year a licensee transfers at least twenty-five per cent of net profits to a reserve fund before any dividend is declared; it may not trade, may not hold more than twenty-five per cent of another bank's paid-up capital and published reserves, and may not buy real estate beyond the needs of its own business and staff.

The bar on residents sits in the statute as well: knowingly accepting or keeping a resident of Dominica as a customer requires the Minister's written approval, and that approval is given for residents generally and may not name a particular person or group.

Reporting is as old-fashioned and as concrete: a statement of assets and liabilities to the Financial Secretary within thirty days of each quarter end, and an auditor-certified annual statement of accounts published in the Dominica Official Gazette within four months of the financial year end, on pain of a fine for every day of delay. The Gazette, not a framed certificate on a website, is the public checkpoint on a Dominican bank.

Transparency is built in: Dominica participates in the CRS and FATCA, non-resident accounts enter automatic exchange with the country of tax residence, and Nodabank, for one, publishes its GIIN on its site. Governing law and the insolvency regime are set by the jurisdiction of the account — the general mechanics are covered in booking centres.

What the regime does not provide

Three things the regime does not provide, and neither the age nor the size of a bank makes up for them. There is no deposit insurance in Dominica: for the currency union's domestic banks the ECCB is only planning a scheme under its 2026–2031 strategic plan, and offshore licensees fall outside its perimeter in any event.

There is no compensation scheme and no banking ombudsman — The Kingdom Bank's terms of use say so in as many words: "There is no banking ombudsman or compensation scheme for financial services in the Commonwealth of Dominica", and the same sentence appears in Sentenor's terms. And each bank builds its own correspondent network: there is no central bank standing behind an offshore licensee.

Crypto operations: a separate regime

Crypto operations sit outside the banking licence. They fall under a separate Virtual Asset Business Act 1 of 2022 with 2024 regulations, and the door there is a different one: registration rather than a licence, over a wider subject than banking, since the Act reaches business conducted both from Dominica and with persons in Dominica.

Operating without registration carries a fine of one hundred and fifty thousand dollars and three years' imprisonment, and Schedule 1 sets the fees: 10,800 dollars to consider an application, 32,400 to register, 6,750 for late payment.

The register's publicity is itself a statutory duty: the FSU must maintain a register of current and suspended registrations showing name, address, type of business, date of registration and status, a register of revoked registrations, and a register of virtual-asset issues, and must publish them on its website. That virtual-asset register carries a warning that entities not listed on the regulator's site are not authorised to conduct that business in Dominica.

A banking licence does not by itself create a right to conduct crypto operations; what it provides is the banking perimeter inside which a crypto product can be booked in the same statement as fiat.

Where the regime came from

Dominica assembled its offshore package in one go in the mid-1990s: the International Business Companies Act 1996, the Offshore Banking Act 1996, the Exempt Insurance Act 1997 and the International Exempt Trust Act 1997 — the standard kit of a Caribbean offshore centre of that era. From there the regime followed the same path as its neighbours.

In 2000 the island appeared on the FATF's first list of non-cooperative jurisdictions and left it in 2002; the Financial Services Unit Act 18 of 2008, in force from 1 January 2009, consolidated supervision of the non-bank and offshore sector in a single authority, and a 2011 amendment gave the FSU oversight of commercial banks' AML compliance.

Between February and October 2021 Dominica sat on the EU tax list and was removed after commitments on information exchange.

The turn that shaped the sector as it stands today is the Virtual Asset Business Act 2022. It carved crypto licensing into a separate regime and, in doing so, let banks hold crypto assets and fiat on one balance sheet. In Europe and North America a bank with that pairing is rare and usually needs separate fintech providers; in Dominica it became the licence's principal product, and all four banks below position themselves exactly that way.

The regime in parameters — what the statute sets, and what follows from it for an account.

The four banks

EQIBank

EQIBank Limited is the oldest of the four and the only one with a coherent public history. The bank launched in October 2018, founded by former bankers from HSBC, Credit Suisse, Bank of New York and UBS under CEO Jason Blick, and presented itself from the outset as "the world's first licensed and regulated bank for national currencies, crypto and digital assets". The product range matches: multi-currency accounts, cards, OTC exchange between crypto and fiat, custody of digital assets, USD/USDT escrow for transactions, and lending secured on digital assets.

According to its licence page the bank is chartered under the Offshore Banking Act No. 8 of 1996 and supervised by the FSU. The 2018 press release also named the Eastern Caribbean Central Bank as a second regulator, but the bank's licence page does not, and by the design of the regime it should not: the ECCB supervises the currency union's domestic banks and has no remit over offshore licensees. There is no official fee schedule on the site — the OTC commission is agreed per transaction — and no public country policy; the only rule that rests on the bank itself is that directors and shareholders of a corporate client must not be citizens of sanctioned countries.

The Kingdom Bank

The Kingdom Bank Corporation is a fully online bank out of Roseau, founded and run by Nebil Serkan Zubari. The product is a multi-currency IBAN across several dozen currencies with BTC, ETH, USDT and USDC balances in the same cabinet, cards, escrow and correspondent payments; the bank invests visibly in recognition, up to and including official global partner status with West Ham United. It evidences information security with ISO/IEC 27001 and PCI DSS certifications (information security policy) and keeps crypto assets in a hot-and-cold wallet arrangement.

The bank describes its licence in two ways. The operative text of its terms of use defines it as "licensed as a bank institution under the Offshore Banking Act" under the prudential supervision of the FSU, with the carve-out "except for Commonwealth of Dominica citizens and residents". The site footer and the about page speak of an "International Banking Act" — no act of that name appears in the FSU's list of legislation, and Dominica's only offshore banking statute is the Offshore Banking Act 1996. Marketing formulas such as "Full Bank" or "equivalent to Class A" do not appear on the bank's site at all; they live in intermediaries' reviews. Payment pricing is fixed (see the table below), and of the card fees the bank has published USD 15 for a physical card and USD 1 for a virtual one.

Nodabank

Nodabank Corporation was incorporated in January 2023 (GLEIF record) and positions itself as a bank with family-office services: a personal manager, purchase and custody of securities through partner brokers, concierge and closed events. The banking side is multi-currency accounts in USD, EUR, CNY and some twenty further currencies, an in-house OTC desk across some twenty crypto pairs, SWIFT and SEPA, crypto deposits and withdrawals free of bank fees, and merchant collection (C2B). The CNY account is a rarity among Dominican banks and the main practical argument for Nodabank among clients with a Chinese trade flow.

The site names only the regulator — "licensed by the Financial Services Unit, Commonwealth of Dominica" — and publishes a GIIN and an LEI, but names neither the act, nor a licence number, nor a separate virtual-asset registration. Pricing is tied to turnover: the larger the monthly volume, the lower the SEPA and SWIFT percentage. Its passport policy is the strictest of the four and the only one stated outright: a passport of the Russian Federation or the Republic of Belarus is a compliance stop criterion — refusal regardless of a residence permit elsewhere, of actual residence outside those countries, and of source of funds. The bank's Russian-language materials address Russian-speaking clients holding other citizenships.

Sentenor Bank

Sentenor Bank Corporation was registered in Dominica in 2025 (number 2025/C0037), its licence is dated 5 March 2025, and the FSU's public search lists the bank with the type Offshore Bank. On its site the bank offers personal banking, investments, wealth management and digital-asset conversion and displays a "Virtual Assets Business Approval", yet the FSU's Virtual Asset Business register carries no Sentenor entry. Remote onboarding does not yet exist: the sign-in and sign-up pages lead to a contact form, an account is opened on request through a manager, and neither a fee schedule nor correspondents are published. The full profile is on the Sentenor Bank page.

Where the banks differ

Under the common label "Dominican offshore bank with crypto" the four are close to indistinguishable: the statute is the same for all, and only the depth of what each bank publishes about its licence varies. They diverge where the decision is actually made — on what basis crypto operations run, what a payment costs, whom the bank will not take, and what stays off the page.

The licence axis barely separates the four, and neither does the crypto axis: none of the banks shows an entry in the Virtual Asset Business register, so at every one of them the crypto permission remains the bank's own statement. Two other axes do the separating — the price of a payment and the passport filter — alongside what each bank leaves off the page.

The first axis is the price of a payment: at Nodabank it is tied to turnover, at The Kingdom Bank it is fixed, and the other two publish no schedule. The second is the passport filter, where only one bank has a policy stated outright. The right-hand column, meanwhile, is the same for all: nobody publishes a correspondent network or a contractual custody model.

Fees

None of the four banks keeps a general price list on its site: The Kingdom Bank has only its card fees in the open, Nodabank issues its tariff in correspondence, and EQIBank and Sentenor publish no prices at all. The rates below are the ones the two banks quote to clients; they become a bank's terms only in a signed offer for a specific account.

The grid should be read against a turnover profile. At modest turnover The Kingdom Bank's fixed SEPA rate beats Nodabank's percentage; at large turnover the proportion inverts, and on outgoing SWIFT the gap favours Nodabank across the whole range. Onboarding and monthly maintenance fees are left out of the comparison: both banks agree them following compliance review, which means they are not a tariff.

Passports and compliance

The passport filter is the one place where the banks truly part ways. Nodabank excludes Russian and Belarusian passports unconditionally. EQIBank and The Kingdom Bank publish no country policy; intermediaries' descriptions paint The Kingdom Bank as the softer of the two, considering applicants who hold a residence permit elsewhere, but nothing of the kind appears in the bank's public documents, and at EQIBank the only rule resting on the bank itself concerns sanctioned citizenships of a corporate client's directors and shareholders. The practical conclusion is simple: for those two banks the passport question is settled by a preliminary enquiry to the bank; a citation to a review does not settle it.

Profile screening itself is built the same way at all four and is no lighter than in Europe: source of funds and source of wealth, sanctions screening, and for a company a website, real activity, directors and beneficial owners from 25%, and notarised documents. The general logic is set out in AML/KYC for the private client and proof of source of funds. A crypto profile adds wallet history and exchange statements: a bank statement documents the operation but does not replace proof of the asset's origin.

Whose balance sheet holds the money, and what happens on insolvency

None of the four banks answers publicly the questions by which the safety of money is measured: on whose balance sheet the balance is booked, whether the client is a direct depositor or a participant in an omnibus account, and who is responsible for custody of investment and digital assets. None of them publishes a contractual custody model or a list of correspondent banks.

Liquidation and the ranking of claims

One of those questions was never addressed to the banks at all: whether there is a priority on insolvency is settled by the Offshore Banking Act itself. Voluntary liquidation requires the Minister's authorisation on the Financial Secretary's recommendation, and only where the bank is solvent, holds liquid assets sufficient to repay depositors without delay, and the decision carries two-thirds of the voting shares; within thirty days the bank must notify every depositor, every other creditor, and everyone whose property it holds as trustee, lessor of a safe deposit box or bailee.

The compulsory route begins with the Minister appointing a receiver — where the realisable value of assets falls below liabilities and capital, where business is conducted unlawfully or imprudently, where continuing harms depositors' interests, or where the licence has been revoked; the Attorney General then petitions the High Court, which may order liquidation, reorganisation, or the return of control to shareholders.

The ranking in compulsory liquidation is set out expressly, and deposits are not last in it:

1. The necessary and reasonable expenses of the receiver and the Official Liquidator.
2. Wages and salaries of the bank's officers and employees for the six months preceding the receiver's appointment, and unpaid social security contributions.
3. Balances of USD 300 and less in savings and time deposits.
4. Other deposits.
5. Taxes and dues owed to Dominica and fees payable to government agencies.

Within a class, if the money falls short, it is distributed pro rata. Property the bank holds otherwise than as debtor is handled separately: the contents of safe deposit boxes and unclaimed property held in custody are transferred by the Official Liquidator to a designated bank and kept for fifteen years.

That ranking should be read soberly. Priority over the state and over creditors the section does not name is not the same thing as insurance: the balance remains a claim against the bank, does not become segregated property and is not guaranteed a return, and the USD 300 threshold was written in 1996 and has never been indexed. There is no compensation layer in Dominica to cap that risk at a limit, and The Kingdom Bank confirms as much in its own terms. The difference between deposit insurance and custody segregation is set out in the banks overview, and for securities in securities custody.

The account terms add a further layer. EQIBank's account agreement contains a right of set-off and general lien: the bank may apply any amounts on any account of the client in any currency towards whatever the client owes the bank. The balance is therefore both unsegregated from the bank's balance sheet and contractually encumbered in the bank's favour. At The Kingdom Bank, Nodabank and Sentenor no equivalent provision is published, and the absence of such a clause from the public text means only that it is undisclosed.

Custody of a digital asset

Custody of a digital asset lives under a different contract — and under a different rule. The 2024 regulations require a registrant holding clients' virtual assets to keep, for each type of asset, an amount larger than its obligations to clients, and require that the asset be held for the client entitled to it, not be the property of the registrant or a third party, not be subject to the claims of their creditors, and not be pledged as collateral in their favour.

A deposit has no such protection — but neither does the rule bite without registration: absent it, the fate of the asset rests on a contract alone. The insurance requirement in the same regulations reads precisely: a registrant insures its own liability for acts and omissions of itself, its officers and its employees, which is professional indemnity rather than a guarantee that a client's asset is safe.

EQIBank refers to insurance of digital assets under custody through Lloyd's of London with a limit of USD 20 million per incident and per policy period; the policy is not described on the bank's public pages, so before assets are transferred it is read in the custody agreement itself — the limit, the exclusions, who the insured party is, and whether the particular asset is covered.

More important than the figure is its nature: a custody insurance policy covers specified events at the custodian and does not answer what becomes of the asset on the bank's insolvency. A bank deposit, segregated custody and custody insurance are three regimes under three different contracts; the general frame for the digital sleeve of a portfolio is set out in crypto for private capital.