| 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. |