Virtual asset regulation and tokenization in Honduras

In Honduras, a business designing virtual asset services must first identify whether it depends on a CNBS-supervised institution. The 2024 restriction affects those institutions and certain customer transactions through their platforms.

Analysis does not end by incorporating outside that perimeter. Check payments, custody, investment offerings and financial infrastructure access, without treating an innovation programme or territorial dispute as a substitute for applicable permission.

How institutional restrictions affect service design

Resolution GEE 069/09-02-2024, communicated through Circular 003/2024 on 12 February, prohibits specified virtual asset operations by institutions supervised by the National Banking and Insurance Commission, CNBS. Its addressees are those institutions; it is not by itself a general criminal prohibition on private holdings or a complete regime for unsupervised businesses.

The CNBS clarification of 22 February 2024 preserves the distinction between the supervised system and operations undertaken at users' own risk. Lack of legal-tender status does not resolve every private contract's effects. Nor does it establish that incorporating an ordinary company permits exchange, custody or fund collection.

Which authority supervises each activity

The CNBS supervises institutions covered by the resolution and the securities market. The Central Bank of Honduras, BCH, acts as monetary authority and authorises and oversees payment services. Electronic Money Agreement 01/2024 distinguishes BCH, CNBS and National Supervisory Council for Cooperatives, CONSUCOOP, responsibilities by entity type.

The Financial Innovation Hub offers dialogue for businesses and initiatives, including foreign ones. Its FAQ expressly states that it grants no licences, permits, certifications or product approvals. Participation or inclusion in a fintech census is neither completion of an authorisation procedure nor an exception to the prohibition.

Which permission the business model requires

Paragraph 1 of the 2024 resolution covers holding, investing, intermediating or dealing in the specified assets where they have not been issued or authorised by the BCH. It also prevents supervised institutions from allowing customers to transact in those instruments through their platforms. A project must identify who performs each service and which financial infrastructure it needs.

Outside that perimeter, the reviewed sources do not establish a general virtual asset service provider licensing route. Consortium Legal's April 2025 analysis distinguishes institutional restrictions from users' exposure. That interpretation does not replace specific permissions or establish that every unsupervised activity is permitted unconditionally.

Próspera claims require separate examination. The ICSID register, case ARB/23/2, lists the arbitration against Honduras as pending, with procedural activity in September 2026. The case establishes a dispute, not the validity of each advertised commercial permission or tax advantage. It is not presented as an alternative national authorisation route, and general tax-exemption promises are not retained.

How holder rights are documented

Articles 1–5 of the Securities Market Law delimit securities, public offerings and registration, involving the CNBS. Digital representation does not remove that analysis where negotiable credit or participation rights exist. Applicable amendments, placement and the relationship between the product and the supervised-institution prohibition require examination.

General securities rules are not equated with express permission to issue or custody any token. A project must also establish evidence of entitlement, transfer mechanics and the effect of divergence between legal and technological records. The examined sources do not establish automatic real estate transfer by token or replacement of corporate or registry formalities.

Which obligations continue during operations

Agreement 01/2024 regulates electronic money as a claim on its issuer, issued against funds, convertible into cash and recorded as a liability, without constituting a deposit or bearing interest. Those characteristics and the entity type matter more than calling an application a wallet. Sharing some features does not authorise a stablecoin; classification and corresponding permissions require verification.

The prohibition also covers assets or liabilities with returns linked to cryptocurrencies or funds indexed to those instruments. It is not confined to direct trading. Preventive obligations must be linked to legally covered persons and activities: using blockchain alone does not establish a financial-intelligence reporting duty for every technology business.

What to prepare before launching the project

Identify supervised institutions involved in receiving funds, custody or settlement and assess operations covered by the resolution. Include indirect exposures linked to cryptoasset returns.

Separate the electronic-money project from virtual asset components and document its permissions. For issuance, specify the right and offering route; for services outside the supervised sector, establish their treatment instead of assuming unrestricted activity.

Treatment of services outside supervised institutions, viable financial relationships and the rights of each issuance remain unresolved. The overall score stays pending. Uncertainty is neither implied permission nor a prohibition on every business activity or blockchain use.

To understand how this framework applies to your project, discuss your case with our team.