Dominica Offshore Banks: Licences, Accounts and Services

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 and Nodabank.

All three 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 and in the price of a payment. 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.

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, has a GIIN. 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 a bank's age or size does not make 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 each bank builds its own correspondent network: there is no central bank standing behind an offshore licensee.

That makes the Dominican licence the cheapest bank on the comparative grid and the thinnest: US$1 million of capital against US$10 million for a Puerto Rico IFE and €5 million on paper for an EU credit institution, with neither a deposit guarantee nor central bank access. The twelve banking licences are compared on those axes in the bank licence grid of the fintech licence map.

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. Entities not on the FSU's virtual-asset register 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 three banks below position themselves exactly that way.

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

The three banks

EQIBank

EQIBank Limited is the oldest of the three 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 Eastern Caribbean Central Bank, named as a second regulator in the 2018 press release, has no remit over offshore licensees: it supervises the currency union's domestic banks. The bank has no published fee schedule — the OTC commission is agreed per transaction; it does not accept corporate clients whose directors or shareholders are citizens of sanctioned countries.

In 2026 the bank's US-dollar channel became the subject of a US forfeiture case. Prosecutors seized funds held in the name of Capstone Limited, a Montana company that, according to EQIBank and the FSU, held dollar funds for the bank, and on 15 July 2026 filed a civil forfeiture complaint against about $83 million and about 1.18 million USDT (United States v. Approximately $79,109,828.17, E.D. Cal.); EQIBank is not a defendant. The bank says the funds belong to it and its depositors and make up about 80% of its financial assets; its motion for their return was denied on 16 July 2026 on jurisdictional grounds, and ownership remains undecided. On 15 June 2026 the FSU placed EQIBank under enhanced supervision; the bank remains on the FSU register.

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", while Dominica's only offshore banking statute is the Offshore Banking Act 1996. The labels "Full Bank" and "equivalent to Class A" come from intermediaries' reviews. Payment pricing is fixed (see the table below), and its card fees include 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. Confirm the account currencies, payment routes, executing entity and digital-asset conversion terms in the bank's offer; for payments from buyers, also confirm whether the service is available and on what contractual terms. For a client trading with China, confirm CNY account availability, the payment route and applicable terms separately; see the Nodabank profile.

Nodabank is licensed by Dominica's Financial Services Unit (FSU) as an offshore bank and has a GIIN and an LEI. It trades as British Atlantic Bank — the legal name change is pending — and admits professional investors, international entrepreneurs and financial institutions by referral only. Its product programme for Q4 2026 sets a one-off onboarding fee of €2,250 per family and company structure and a single charge of 0.75% per payment-and-conversion cycle that the bank waives for a structure holding $1 million or more in cash, deposits and cash collateral.

Where the banks differ

Under the common label "Dominican offshore bank with crypto" the three are close to indistinguishable: the statute is the same for all. They diverge where the decision is actually made — on what basis crypto operations run, what a payment costs, and whom the bank will not take.

The licence axis barely separates them, and neither does the crypto axis. Two other axes matter — the price of a payment and the passport question.

The first axis is the price of a payment: The Kingdom Bank charges a fixed fee plus a percentage, Nodabank a single cycle charge waived above a balance threshold, and EQIBank agrees its exchange commission per transaction.

Fees

None of the three banks has a general public price list: The Kingdom Bank publishes only its card fees, and EQIBank has no published prices. The rates below are those The Kingdom Bank quotes to clients and those set in Nodabank's Q4 2026 product programme; they become a bank's terms only in a signed offer for a specific account.

The grid should be read against the client's balance as well as turnover. Both schedules charge per transaction: The Kingdom Bank a fixed fee plus a percentage per payment, Nodabank 0.75% per cycle of receipt, conversion and onward payment. Nodabank waives its own commission for a structure that keeps $1 million or more with the bank in cash, deposits and cash collateral; correspondent, network and third-party charges remain. The Kingdom Bank agrees onboarding and maintenance fees following compliance review; Nodabank charges a fixed onboarding fee and no monthly maintenance fee.

Passports and compliance

None of the three banks has a public country policy. Nodabank admits clients only by referral and after due diligence. Intermediaries describe The Kingdom Bank as softer than EQIBank, considering applicants who hold a residence permit elsewhere; EQIBank does not accept corporate clients whose directors or shareholders are citizens of sanctioned countries. The practical conclusion is simple: for all three 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 three 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

Assess the position of client money and assets under the account and custody agreements, and the payment route against the specific instruction. Nodabank publishes a Bank Account Agreement; confirm whether that version applies to the selected product programme, the custodian and the segregation terms for the particular assets before transferring funds.

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 outside that list 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. 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. Nodabank's published account agreement contains a comparable right: it keeps any set-off or general lien the bank has at law and lets the bank apply money in any account and client assets held with an affiliate against debts owed to the bank or its affiliates.

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; before assets are transferred, the custody agreement itself is checked for 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.