Outside the EU there is no single crypto regime: depending on the country, a virtual asset business needs a licence, an authorisation, a registration or membership of a self-regulatory organisation. We help choose the regime that fits the model and target markets, and prepare the company, documents, AML framework and systems for it.
A virtual asset service provider (VASP) exchanges, transfers, holds or arranges transactions in virtual assets for clients. Each jurisdiction defines the perimeter itself, and the resulting status differs in legal nature: in Dubai it is a licence from the Virtual Assets Regulatory Authority (VARA); in the United Kingdom it is currently a registration with the Financial Conduct Authority (FCA) under the Money Laundering Regulations; in Switzerland it is membership of a self-regulatory organisation (SRO); in Canada it is a registration with FINTRAC, which is not a licence.
The choice of jurisdiction therefore depends on more than capital: target clients, banking and payment partners, required local substance, whether the regime is stable or in transition, and which markets the status actually opens. A status in one country does not by itself permit serving clients in another country that has its own regime. For example, the European Securities and Markets Authority (ESMA) has stated that non-EU providers may not serve clients in the EU.
Kazakhstan has two separate frameworks: the national regime, where the National Bank of Kazakhstan supervises digital asset service providers, and the regime of the Astana International Financial Centre (AIFC), supervised by the Astana Financial Services Authority (AFSA). They are not interchangeable and are covered on dedicated pages, as is MiCA authorisation in the EU.
Only regimes and figures confirmed against official sources as of 15 October 2026 are shown. Capital and other figures are regulatory minimums, not total project costs.
| Jurisdiction | Regulator | Regime | Key points |
|---|---|---|---|
| UAE — Dubai (except DIFC) | VARA (Virtual Assets Regulatory Authority) | Licence | Eight activities, each with its own rulebook. Two stages: approval to incorporate (no virtual asset activity yet), then the VASP licence. Paid-up capital from AED 100,000 (advisory) to the higher of AED 1.5 million and 25% of annual fixed overheads (exchange), summed across activities; net liquid assets of at least 1.2 months of operating expenses. |
| UAE — federal (outside Dubai and financial free zones) | Capital Market Authority (CMA), formerly SCA | Licence | The CMA replaced the Securities and Commodities Authority (SCA) from 1 January 2026 and announced a new virtual assets framework with eight regulated activities on 13 April 2026. Capital and transitional rules are confirmed against the official text at assessment. |
| UAE — ADGM and DIFC | FSRA (ADGM); DFSA (DIFC) | Financial services permission (ADGM); licence (DIFC) | ADGM (Abu Dhabi Global Market): permission issued after in-principle approval and fulfilment of its conditions; base capital depends on the prudential category. DIFC (Dubai International Financial Centre): since 12 January 2026 the firm assesses the suitability of each crypto token itself; the DFSA no longer keeps a list of recognised tokens. |
| United Kingdom | Financial Conduct Authority (FCA) | Registration now; authorisation from 2027 | Exchange and custodian wallet providers register under the Money Laundering Regulations 2017. New regime under the Financial Services and Markets Act (FSMA, SI 2026/102): application window 30 September 2026 – 28 February 2027, regime start on 25 October 2027, no automatic transfer from the existing register. |
| Switzerland | SRO recognised by FINMA | SRO membership (not a licence) | Trading in virtual currencies is financial intermediation under the Anti-Money Laundering Act (AMLA); the intermediary must join an SRO, which supervises it. Collective custody of crypto-assets and DLT trading facilities require FINMA licences. New licence categories for payment instrument and crypto institutions were the subject of a consultation that closed on 6 February 2026. |
| Hong Kong | Securities and Futures Commission (SFC) | Licence | Operating a virtual asset trading platform requires an SFC licence, with requirements on custody, KYC, AML/CFT, conflicts of interest, token admission, market abuse and cybersecurity. Separate VA dealing and custody regimes were set out in consultation conclusions of December 2025, with legislation intended in 2026. |
| Canada | FINTRAC; Revenu Québec in Québec | MSB registration (not a licence) | Dealing in virtual currency is a money services business (MSB) activity. Foreign MSBs serving clients in Canada must register before starting operations. Registration expires unless renewed every two years and requires a compliance programme. Québec requires a separate licence, including for crypto ATMs. |
| Seychelles | Financial Services Authority (FSA) | Licence | VASP Act 2024; unlicensed activity prohibited from 1 January 2025, including for companies serving only foreign clients. Capital: wallet USD 75,000, exchange USD 100,000, broker USD 50,000, investment provider USD 25,000. Resident director, in-house compliance officer (no outsourcing), board and management meetings in Seychelles. |
| British Virgin Islands | Financial Services Commission (FSC) | Registration | VASP Act 2022. No fixed minimum capital: resources must match size, complexity and risk, with higher expectations for exchanges and custodians. An authorised representative is required; corporate directors are not permitted. |
| Cayman Islands | Cayman Islands Monetary Authority (CIMA) | Licence (custody, trading platforms); registration (other) | Since 1 April 2025 custody and trading platform services require a licence; other VASP activity is registered. Licensees need at least three directors and must meet enhanced prudential requirements. |
| Kyrgyzstan | Service for Regulation and Supervision of the Financial Market; National Agency for Virtual Assets and Blockchain Technologies | Licence (issuing authority confirmed at assessment) | Virtual asset activity is governed by the Law on Virtual Assets, substantially amended in January 2026. Under a Cabinet of Ministers resolution adopted in July 2026, supervision, licensing control and AML/CFT oversight of virtual asset service providers rest with the Service for Regulation and Supervision of the Financial Market; a National Agency for Virtual Assets and Blockchain Technologies was created in May 2026 and has taken over part of the Service's functions. Which body issues a licence for a new project, and the applicable capital, are confirmed against the official texts at assessment. |
| Georgia | National Bank of Georgia (NBG) | Registration | Registered services include exchange (including kiosks), transfer, custody and administration, operating a trading platform, lending and initial coin offerings; only convertible virtual assets are in scope. Amendments of 8 September 2026 set minimum supervisory capital: GEL 150,000 for exchange and/or transfer, GEL 350,000 for operating a trading platform, GEL 250,000 for other services and from GEL 500,000 for a stablecoin offering; where several services are provided, the highest amount applies. Existing VASPs must have a risk management framework in place by 1 July 2027 and meet the capital requirement by 1 September 2027. |
Regulatory capital is separate from state and application fees, operating costs and our fees. Our fees are agreed after the project assessment.
We identify target clients and countries and which regimes apply to them. Result: a map of required statuses.
We compare legal nature, capital, substance, timing and banking considerations. Result: a recommended jurisdiction and structure.
Company, directors, local presence and capital in line with the regime. Result: the applicant entity.
Business plan, financial model, policies, AML programme and IT documentation. Result: the application filed.
Responses, interviews and fulfilment of the conditions of in-principle approval. Result: licence, registration or membership.
Systems go-live, reporting set-up and first compliance reviews. Result: an operating VASP.
Most of these regimes have no single statutory decision period that can be relied on for planning. Fixed dates exist where the law sets them: the FCA accepts applications under the new UK regime from 30 September 2026 to 28 February 2027, and the regime starts on 25 October 2027. Staged processes, such as VARA's approval to incorporate or ADGM's in-principle approval, add steps between filing and the final status. Real timelines depend on the regulator, the completeness of the file and the number of question rounds; no decision date can be promised.
Authorisation of a crypto-asset service provider under MiCA in an EU Member State, with a passport to serve clients across the Union.
Learn moreBuying, selling and exchanging digital assets for clients: exchange services, online exchangers, in-app exchange.
Learn moreSafekeeping of client assets and keys; custody infrastructure for exchanges, exchangers and platforms.
Learn moreVenues where clients trade digital assets with each other through the operator's trading system.
Learn moreExecuting client orders, agency models, access to foreign venues and liquidity.
Learn moreRisk assessment, policies, KYC/KYB, sanctions and transaction monitoring, travel rule and inspection readiness for licensed and to-be-licensed financial and crypto businesses.
Learn moreDescribe your project in a few sentences. We will give you a substantive reply: which questions need answering and where to start.
Discuss your projectNo. A financial intermediary trading in virtual currencies must join an SRO recognised by FINMA, and the SRO supervises it. Activities such as collective custody of crypto-assets or operating a DLT trading facility require separate FINMA licences.
The new UK regime starts on 25 October 2027, and there is no automatic transfer from the current register. A firm that wants to continue must apply for authorisation; the window runs from 30 September 2026 to 28 February 2027. The position of firms that miss the window has to be assessed individually.
It depends on where the company is established and what it does. In Dubai (except DIFC) the regulator is VARA; in the rest of the UAE outside the financial free zones, the CMA; in ADGM, the FSRA; and in DIFC, the DFSA. Payment token services fall under the Central Bank of the UAE.
It is a mandatory registration, not a licence, and FINTRAC does not approve the business. Québec requires a separate licence, and platforms dealing in crypto contracts may also fall under provincial securities rules, which we assess separately.
No. ESMA has stated that non-EU providers may not serve clients in the EU, and UK rules on cryptoasset financial promotions apply to overseas firms targeting UK consumers. Access to these markets requires the local status or a structure with an entity holding it.
In Singapore, firms based there that serve only overseas clients face a regime under which licences are reported to be granted only in extremely limited circumstances. Mauritius licenses virtual asset services under the VAITOS Act; capital rules are confirmed against current FSC texts before we give figures.
They are two separate regimes: the National Bank of Kazakhstan supervises digital asset service providers under national law, except AIFC participants, who are supervised by AFSA. Each has its own page on this site.
Describe the services, target clients and markets. We will return with a short comparison of suitable regimes, the status each gives and the scope of work; our fees are agreed after this assessment.
We will review the description and give you a substantive reply: which regime may apply and where to start.
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