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Conclusion Existing BVI legislation, as supported by the Guidance, is sufficiently flexible to support ICOs of utility tokens without these being subject to any additional licensing, disclosure or record keeping obligations under existing BVI financial services legislation. While other offshore jurisdictions have experienced similar interest, the relative advantages of using a BVI company to create and offer new cryptocurrencies have now made the BVI a leading ICO base. In recent years, substantial amounts have been raised through initial coin offers ICOs for cryptocurrencies, tokens, and other blockchain-based assets. Where a person acts as custodian or depository of assets belonging to another person, and that asset has been defined as an investment, that person is providing Custodial Services.