# Dominica Offshore Banks: One Licence, Four Products

> EQIBank, The Kingdom Bank, Nodabank and Sentenor Bank: one statute, the Offshore Banking Act 1996, a separate virtual asset regime, fees and no deposit insurance.

Author: Ksenia Voronova — Lawyer, Family Office (https://wiki.private.law/en/authors/voronova)
Last modified: 2026-08-31T18:11:00.000Z
Canonical: https://wiki.private.law/en/dominica-offshore-banks
Topics: banking
Jurisdictions: dominica
Product tags: banking, bank, custody
Semantic tags: banking, bank, custody

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The corpus described EQIBank, The Kingdom Bank and Nodabank as three different Dominican banking regimes. Primary sources show otherwise: the statute is one and the same. What actually separates these banks is the price of a payment, the passport filter, and how much they decline to disclose.

## Concept

A Dominican offshore bank is a licensee under the Offshore Banking Act 1996, supervised by the Financial Services Unit \(FSU\) of the Ministry of Finance. The construction runs parallel to the domestic banking system and does not compete with it: the licence permits international business with non-resident personal and corporate clients and expressly excludes citizens and residents of Dominica. Everything else follows from that prohibition — both the breadth of the product shelf and the weak spot.

The regime withholds three things, and neither the age nor the size of a bank compensates for any of them. Dominica has no deposit insurance system. There is no banking ombudsman and no compensation scheme for financial services — a licensee admits as much in its own terms of service. And the correspondent network is built by the bank itself rather than inherited from a central bank.

Digital asset operations sit outside the banking licence: they fall under a separate Virtual Asset Business Act 1 of 2022, and the FSU keeps a separate public register for it. A banking licence does not by itself create the right to conduct crypto operations.

Transparency is built into the regime. Dominica participates in [CRS](https://wiki.private.law/en/crs-overview) and FATCA, and non-resident accounts enter automatic exchange with the country of tax residence. Governing law and the insolvency regime are set by the jurisdiction of the account rather than by the bank's brand — the general mechanics are covered in [booking centres](https://wiki.private.law/en/booking-centres).

## One licence presented as two

This is the discrepancy the page exists to resolve.

**EQIBank.** The bank's own [licence page](https://eqibank.com/legal/license/) states that it is chartered under the Offshore Banking Act No. 8 of 1996 of the Commonwealth of Dominica, "which allows international business with non-resident personal and corporate clients", supervised by the FSU. There is no second regulator: the claim that EQIBank is also regulated by the Eastern Caribbean Central Bank is not supported by the bank's public materials — the ECCB supervises domestic banks of the currency union, not offshore licensees.

**The Kingdom Bank.** The account of a "Full Bank licence under the International Banking Act, equivalent to Class A" fails on three counts. The operative text of the bank's own [terms of use](https://www.thekingdombank.com/terms-of-use) defines it as "licensed as a bank institution under the Offshore Banking Act \(the 'Law'\)" and refers the reader to the FSU register of licensed offshore banks. The phrase "International Banking Act" appears only in the site footer and on the about page, while the [FSU list of legislation](https://www.fsu.gov.dm/legislation) contains no such act at all — what it lists is the Offshore Banking Act, 1996. And the words "Full Bank" and "Class A" appear nowhere on the bank's site.

**Nodabank.** Its own site names only the regulator — "licensed by the Financial Services Unit, Commonwealth of Dominica" — and names neither the act, nor a licence number, nor any separate virtual asset registration.

Conclusion: EQIBank and The Kingdom Bank are licensed under one and the same statute; there are not two regimes. What read as a difference of licences is a difference of self-description. A related observation: The Kingdom Bank's footer drops the carve-out that stands in the operative text — "except for Commonwealth of Dominica citizens and residents". One document describes the perimeter of admission in two ways that do not match.

## What the licence permits, and what stays outside it

On EQIBank's own wording, the statute permits international business with non-residents; accounts are not subject to local taxes or exchange restrictions, and funds in foreign currencies transfer freely with no conversion into the East Caribbean dollar. That is precisely what the licence delivers.

Three things stay outside it. The right to serve citizens and residents of Dominica — prohibited outright. Compensation for a depositor — The Kingdom Bank states plainly in its terms: "There is no banking ombudsman or compensation scheme for financial services in the Commonwealth of Dominica." And the right to conduct virtual asset operations — a separate permission under the Virtual Asset Business Act 1 of 2022 with its own FSU register.

Entries for the three banks in the virtual asset register could not be independently confirmed in the check of 31 August 2026: the FSU search works only as an interactive form and serves no static result pages. The regulator warns that entities absent from its site are not authorised to conduct the corresponding business in Dominica. Until an entry is produced, crypto permissions remain the bank's own assertion. The same gap between asserted and confirmed is examined in detail on [Sentenor Bank](https://wiki.private.law/en/sentenor-bank).

## Where the banks actually differ

Under the common label "Dominican offshore bank with crypto" the four are indistinguishable. They diverge exactly where the decision is made: what confirms the licence, on what basis crypto operations run, what a payment costs, and who the bank will not take.

| Bank | Statute per primary source | Basis for crypto operations | Price of a payment | Russian and Belarusian passports | Not disclosed |
| --- | --- | --- | --- | --- | --- |
| EQIBank | Offshore Banking Act No. 8 of 1996, supervised by the FSU. Stated on the bank's licence page | Custody and OTC exchange asserted; no Virtual Asset Business register entry produced | No fee schedule on the site; OTC commission agreed per transaction | No public country policy; corpus descriptions contradicted each other | Correspondents, custody contract, minimum balance, insolvency treatment |
| The Kingdom Bank | Offshore Banking Act in the operative text of its terms; "International Banking Act" only in the site footer | A separate FSU digital assets licence asserted; no register entry produced | SEPA €1 + 0.5%; SWIFT in €50 + 1%, out €5 + 2%; crypto ↔ fiat conversion 2% | Case-by-case with residence elsewhere asserted; no public country policy | Correspondents, a general fee schedule on the site, custody contract, insolvency treatment |
| Nodabank | No act named; the site gives only the regulator, the FSU | A virtual asset registration asserted; not named on the bank's own site | SEPA 0.55–0.35% and SWIFT 0.95–0.6% by turnover tier; crypto conversion 0.75%; crypto deposit and withdrawal free of bank fee | Refusal. A Russian or Belarusian passport is a stop criterion regardless of residence permit or source of funds | Correspondents, licence number, custody contract, insolvency treatment |
| Sentenor Bank | Offshore Bank type confirmed by the FSU register card; number, class and conditions of the licence not disclosed by the register | The site displays a "VAB Approval"; no Virtual Asset Business register entry as of 30.08.2026 | No official fee schedule | Acceptable passports not published | Remote onboarding not live; correspondents, protection of balances, custody |

The table shows that the licence axis barely separates the four: the statute is common to them, and only the depth of confirmation differs. Two other axes do the separating. The first 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 at all. The second is the passport filter, and here exactly one bank of four is unambiguously disclosed. The right-hand column, meanwhile, is identical for all: nobody publishes a correspondent network or a contractual custody model.

## Fees: what is actually published

The grid below is carried over from the bank profiles and checked on 31 August 2026. That check produced a material result: neither The Kingdom Bank nor Nodabank has a public page carrying a general fee schedule — what was publicly available at The Kingdom Bank was card fees only \(physical card USD 15, virtual USD 1, announcement of 28 January 2026\). The rates below should therefore be treated as recorded in the corpus rather than as a bank's live published tariff, and confirmed in the offer for a specific account.

| Operation | The Kingdom Bank | Nodabank |
| --- | --- | --- |
| SEPA, in and out | €1 + 0.5% | 0.55% up to €1M/month turnover; 0.45% at €1–5M; 0.35% at €5–50M and above |
| SWIFT, incoming | €50 + 1% | 0.95% up to €1M/month turnover; 0.8% at €1–5M; 0.6% at €5–50M and above |
| SWIFT, outgoing | €5 + 2% | same turnover grid |
| Crypto ↔ fiat conversion | 2%, discounted on volume | 0.75%, including crypto-to-crypto |
| Fiat ↔ fiat conversion | not published | 0.5% |
| Crypto deposit and withdrawal | not published | no bank fee; network fee paid by the client |
| Internal transfer between the bank's clients | not published | free |
| Accepting payments from buyers \(C2B\) | no such product | 3.5% of full turnover, fiat or crypto |

The grid should be read against a turnover profile, not line by line. 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 describe them as agreed following compliance review, which means they are not a tariff.

## Russian and Belarusian passports

Only Nodabank is unambiguously disclosed here: 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 and are not a signal that Russian passports are accepted.

For the other two banks there is no public country policy, and the corpus contradicted itself: the Russian and English profiles of EQIBank asserted different things — in one the passport was subject to an individual filter, in the other an unconditional refusal. Neither version is supported by the bank's materials. The only statement here that rests on the bank is the requirement that directors and shareholders of a corporate client not be citizens of sanctioned countries. The Kingdom Bank was described as softer, but that too is not recorded in its public documents.

The practical conclusion: for EQIBank and The Kingdom Bank the passport question is settled by a preliminary enquiry to the bank, not by a citation to a review. The general logic of profile screening is set out in [AML/KYC for the private client](https://wiki.private.law/en/aml-kyc-private-client) and in [proof of source of funds](https://wiki.private.law/en/source-of-funds).

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

None of the three banks answers publicly the four 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; whether there is segregation or a statutory priority on insolvency; and who is responsible for custody of investment and digital assets. Neither EQIBank, nor The Kingdom Bank, nor Nodabank publishes a contractual custody model or a list of correspondent banks.

General rules nonetheless settle part of it. A deposit under an offshore banking licence is an unsecured claim against the bank itself, not segregated property: the balance is booked on the licensee's balance sheet, and on its insolvency the client becomes an ordinary unsecured creditor in the liquidation. 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](https://wiki.private.law/en/banks), and for securities in [securities custody](https://wiki.private.law/en/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 not merely unsegregated from the bank's balance sheet but contractually encumbered in the bank's favour. Equivalent provisions at The Kingdom Bank and Nodabank are not published, and that should be read as undisclosed rather than absent.

Two situations that the profiles blurred are worth separating. The bank's insolvency strikes the cash balance. Custody of a digital asset lives under a different contract, and its fate depends on whether the asset is booked to the client on a segregated basis — which is exactly what none of the three discloses.

## Custody of digital assets

EQIBank asserted insurance of digital assets under custody through Lloyd's of London with a limit of USD 20 million per incident and per policy period. In the check of 31 August 2026 this assertion was not found on the bank's public pages: the licence, about, custody and escrow sections do not carry it, and the FAQ page to which it was traced returns a 404. The claim is therefore carried over as a bank assertion recorded in the corpus, and before signing it requires verification against 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 is not a state deposit guarantee. It 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 must not be conflated — they 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](https://wiki.private.law/en/crypto-private-wealth).

> ⚠️ **A bank's self-description is not its licence.** "International Banking Act", "Full Bank" and "equivalent to Class A" are formulations from marketing pages, not from a statute: no such act appears in the FSU list of legislation, and the same bank's operative terms cite the Offshore Banking Act. The legal boundaries of a permission are set by a regulator's entry or by a copy of the licence instrument.
> **Crypto permission is a separate authorisation.** A banking licence does not cover virtual asset operations: those fall under the Virtual Asset Business Act 1 of 2022 with its own FSU register. An image of a certificate on a website is not a register entry.
> **The balance is an ordinary claim against the bank.** Dominica has no deposit insurance, no compensation scheme and no banking ombudsman; on a licensee's insolvency the client joins the general queue of creditors, and under the account contract the balance may additionally be encumbered by a right of set-off in the bank's favour.
> **An unpublished rate is not a tariff.** None of the four banks keeps a general price list on its site; rates taken from reviews do not become a bank's terms until they appear in its own schedule or in a signed offer.

## Q/A

### Are these different banking regimes or one

One. The Offshore Banking Act 1996 is the only offshore banking statute of Dominica in the FSU list of legislation; "International Banking Act" does not appear there, and the operative text of The Kingdom Bank's terms cites the Offshore Banking Act. The difference between the bank profiles was a difference of wording, not of licences.

### What exactly does a Dominican offshore licence permit

International business with non-resident personal and corporate clients. Accounts are not subject to local taxes or exchange restrictions, and funds in foreign currencies transfer without conversion into the East Caribbean dollar. A licensee may not serve citizens and residents of Dominica.

### Does a banking licence cover crypto operations

No. That is a separate permission under the Virtual Asset Business Act 1 of 2022, for which the FSU maintains a separate public register. The regulator warns that entities absent from its site are not authorised to conduct such business in Dominica, so a certificate displayed on a bank's website does not substitute for a register entry.

### What happens to the balance if the bank becomes insolvent

The balance is booked on the bank's own balance sheet and the client becomes an ordinary unsecured creditor. Dominica has no deposit insurance system, no compensation scheme and no banking ombudsman for financial services — the last of which The Kingdom Bank states in its own terms of service. None of the three banks publishes client-money segregation, a list of correspondents, or a contractual custody model.

### Will these banks open an account on a Russian or Belarusian passport

An unambiguous public answer exists only for Nodabank: refusal regardless of a residence permit elsewhere, of residence outside Russia and Belarus, and of source of funds. EQIBank and The Kingdom Bank publish no country policy, and the descriptions in reviews contradicted one another, so the question is settled by a preliminary enquiry to the bank.

### Which of them is cheaper on payments

It depends on turnover. At modest turnover The Kingdom Bank's fixed SEPA rate beats Nodabank's percentage grid; at large turnover the advantage passes to Nodabank, and on outgoing SWIFT it holds across the whole range. EQIBank and Sentenor Bank publish no schedule at all. Onboarding and maintenance fees are not a tariff: both banks describe them as agreed following compliance review.

### Is a Dominican bank suitable for core capital

No. Without deposit insurance, without a lender of last resort and without a disclosed custody chain, such an account is unfit for a passive balance — it solves narrow tasks: a multi-currency payment perimeter, OTC exchange inside a banking perimeter, escrow for a transaction. Core capital belongs with [private banking](https://wiki.private.law/en/private-banking) in a mature jurisdiction; a comparison of offshore banking centres that do operate compensation schemes is in [offshore banking jurisdictions](https://wiki.private.law/en/offshore-banks).

> 🍓 Dominican banks differ by product and by fee, not by regime: EQIBank and The Kingdom Bank are licensed under a single statute, the Offshore Banking Act 1996, while "International Banking Act", "Full Bank" and "Class A" exist only in marketing copy. The licence grants international business with non-residents and forbids serving residents of Dominica; it does not cover crypto operations, which require separate standing under the Virtual Asset Business Act 1 of 2022 with an FSU register entry that none of the banks has publicly produced. Dominica has no deposit insurance, no compensation scheme and no ombudsman: the balance sits on the bank's balance sheet, becomes an ordinary claim in liquidation on insolvency, and under the account contract may be encumbered by a right of set-off in the bank's favour. Two things do separate these banks — the price of a payment against a turnover profile, and the passport filter, of which only Nodabank's refusal of Russian and Belarusian passports is publicly disclosed. Data checked on 31 August 2026.

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## Factual claims

- A Dominican offshore bank is a licensee under the Offshore Banking Act 1996, supervised by the Financial Services Unit (FSU) of the Ministry of Finance.
- Digital asset operations sit outside the banking licence: they fall under a separate Virtual Asset Business Act 1 of 2022, and the FSU keeps a separate public register for it.
- Entries for the three banks in the virtual asset register could not be independently confirmed in the check of 31 August 2026: the FSU search works only as an interactive form and serves no static result pages.
- The grid below is carried over from the bank profiles and checked on 31 August 2026.
- EQIBank asserted insurance of digital assets under custody through Lloyd's of London with a limit of USD 20 million per incident and per policy period.

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