30/10/2026
Several licensed International Financial Entities serve the digital asset industry, which leads many founders to assume an IFE can run an exchange. It cannot.
Act 273 draws the line clearly. An IFE may provide custody of digital assets for clients with a no-objection letter from the Commissioner, offer US dollar deposit accounts and payment services to non-resident clients, lend against digital assets within its approved business plan, and provide treasury and trust services to non-residents.
It may not operate a virtual currency exchange, serve residents of Puerto Rico outside narrow exceptions, or count digital assets toward its $10,000,000 paid-in capital.
The structure that works is a group: an exchange entity licensed as a money transmitter, an IFE for custody and banking, and an export services company for technology, each with its own compliance program.
Swipe for the line, then get the free IFE guide through the link in the comments.
Free IFE guide at lawyerinpr.com/ife-guide
Free initial evaluation at lawyerinpr.com/start
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