Kazakhstan is our core market: we work under the national regime and in the AIFC. For international projects we compare regimes verified against official sources and work with local counsel where foreign law requires it.
National Bank of Kazakhstan and the Agency for Regulation and Development of the Financial Market.
Astana Financial Services Authority under AIFC law.
Regimes verified against official sources as of 15 October 2026. Requirements change, so the final list for your project is confirmed at the assessment stage.
National Bank of Kazakhstan (NBK); Agency for Regulation and Development of the Financial Market (ARDFM)
Since 1 May 2026, operators exchanging unbacked digital assets are licensed by the NBK, while digital asset trading platforms register with it; the law provides 20 working days to review a licence application. Payment organisations also register with the NBK, and banks and securities market participants are licensed by the ARDFM.
Astana Financial Services Authority (AFSA)
A separate regime that applies only to AIFC participants: AFSA authorises digital asset trading facilities and service providers, investment firms, money services and banking. A digital asset trading facility must hold capital of at least the higher of USD 200,000 and 12 months of operating expenses.
National Bank of the Kyrgyz Republic (NBKR); Service for Regulation and Supervision of the Financial Market; National Agency for Virtual Assets and Blockchain Technologies
The NBKR licenses banks, payment organisations and currency exchange bureaus: a new payment organisation needs charter capital of at least KGS 30 million, and a new exchange bureau needs working capital of KGS 5 million in Bishkek and Osh or KGS 3 million elsewhere. Virtual asset service providers are supervised by the Service for Regulation and Supervision of the Financial Market, and a National Agency for Virtual Assets was set up in May 2026; which body issues a licence for a new project is confirmed at the assessment stage.
National Bank of Georgia (NBG)
Virtual asset service providers (VASPs), payment service providers and currency exchange bureaus register with the National Bank of Georgia, while banks are licensed by it. Amendments of 8 September 2026 set minimum supervisory capital for VASPs at GEL 150,000 for exchange and transfer, GEL 350,000 for operating a trading platform and GEL 250,000 for other services; existing VASPs must comply by 1 September 2027.
Bank of Lithuania; European Central Bank (bank licences)
The Bank of Lithuania is the competent authority for MiCA crypto-asset service providers, and the transitional period for existing providers ended on 31 December 2025. Lithuania also offers a specialised bank licence with initial capital of EUR 1 million and a separate list of currency exchange operators.
Czech National Bank (CNB)
The CNB became the MiCA competent authority under Act No. 31/2025 Coll. and had granted MiCA authorisation to 11 entities by 1 July 2026. Currency exchange is a separately licensed activity under Act No. 277/2013 Coll.
Finantsinspektsioon (Financial Supervision Authority); Financial Intelligence Unit (FIU)
Since 30 December 2024, crypto-asset service providers have been authorised by Finantsinspektsioon; the Financial Intelligence Unit no longer issues virtual asset authorisations but remains the AML supervisor.
Cyprus Securities and Exchange Commission (CySEC)
CySEC authorises investment firms, including CFD brokers, which must apply restrictions when offering CFDs to retail clients. The MiCA transitional period in Cyprus has expired, so crypto-asset services now require full MiCA authorisation.
Malta Financial Services Authority (MFSA); Financial Intelligence Analysis Unit (FIAU)
Malta has moved from its national virtual financial assets regime to MiCA: the transitional measures expired on 30 June 2026, and VFA licence holders had to obtain a CASP licence or wind down. The MFSA also supervises company service providers, including a notification regime for restricted providers.
Financial Conduct Authority (FCA); Prudential Regulation Authority (PRA); HM Revenue and Customs (HMRC)
Cryptoasset exchanges and custodian wallet providers currently register with the FCA under the Money Laundering Regulations; a full FCA authorisation regime takes effect on 25 October 2027, with applications accepted from 30 September 2026 to 28 February 2027. Payment and e-money institutions, investment firms and banks are authorised separately.
Swiss Financial Market Supervisory Authority (FINMA); FINMA-recognised self-regulatory organisations (SROs); supervisory organisations (AOs)
Trading in virtual currencies falls under the Anti-Money Laundering Act and requires membership of a FINMA-recognised self-regulatory organisation, which is not a licence. FINMA licenses banks, securities firms and DLT trading facilities; the FinTech licence allows a firm to accept public deposits of up to CHF 100 million.
Virtual Assets Regulatory Authority (VARA)
VARA licenses eight types of virtual asset activity in Dubai, including its free zones but excluding the DIFC. Licensing has two stages: an Approval to Incorporate, which does not yet permit virtual asset activity, followed by the VASP licence.
Capital Market Authority (CMA), formerly the Securities and Commodities Authority (SCA)
From 1 January 2026 the federal regulator SCA was replaced by the Capital Market Authority, which covers virtual asset service providers outside Dubai and the financial free zones. The CMA announced a new virtual assets framework in April 2026; its detailed requirements are confirmed against the official text at the assessment stage.
Central Bank of the UAE (CBUAE)
The CBUAE licenses retail payment service providers in four categories, stored value facilities and exchange houses, and, under the Payment Token Services Regulation in force since 31 August 2024, payment token issuers, custodians and conversion providers. Its regime applies onshore and in non-financial free zones, not in the DIFC or ADGM.
Financial Services Regulatory Authority (FSRA) of ADGM
The FSRA grants a Financial Services Permission for virtual asset activities, fiat-referenced token issuance, money services, investment and banking business. Before the permission is issued, the applicant receives an in-principle approval with conditions on capital, staff, registration and premises.
Dubai Financial Services Authority (DFSA)
The DFSA regulates crypto token activities, money services, investment firms and banks in the DIFC. Since 12 January 2026 the DFSA no longer publishes a list of recognised crypto tokens, and each firm must assess and document the suitability of every token itself.
Securities and Futures Commission (SFC); Hong Kong Monetary Authority (HKMA); Customs and Excise Department; Companies Registry
Virtual asset trading platforms are licensed by the SFC, and issuers of fiat-referenced stablecoins by the HKMA, which granted its first licences on 10 April 2026. Money service operators are licensed by the Customs and Excise Department; regimes for virtual asset dealing and custody were set out in consultation conclusions in December 2025.
Monetary Authority of Singapore (MAS)
Under the Payment Services Act, MAS issues three classes of licence: money-changing, standard payment institution and major payment institution. A standard payment institution needs base capital of SGD 100,000 and moves to the major licence once its monthly volumes exceed the statutory thresholds.
Financial Services Authority (FSA)
Under the Virtual Asset Service Providers Act 2024, unlicensed virtual asset activity has been prohibited since 1 January 2025; an exchange needs initial capital of USD 100,000, a resident director and an in-house compliance officer. The FSA also licenses securities dealers under the Securities Act 2007.
Financial Services Commission (FSC)
The Virtual Asset and Initial Token Offering Services Act 2021 provides separate licence classes for broker-dealers, wallet services, custodians, advisory services and marketplaces. Investment dealers are licensed under the Securities Act 2005, with minimum capital set by licence category.
Financial Services Commission (FSC)
Virtual asset service providers register with the FSC under the VASP Act 2022; there is no fixed minimum capital, but capital must match the size and risks of the business, and an authorised representative is mandatory. Investment business is licensed under separate legislation.
Cayman Islands Monetary Authority (CIMA)
Since 1 April 2025, virtual asset custody and trading platforms require a CIMA licence, while other virtual asset services are subject to registration; licensees need at least three directors. Securities investment business has its own licensing regime.
Vanuatu Financial Services Commission (VFSC)
The Virtual Asset Service Providers Act No. 3 of 2025 introduced licences for exchange, transfer, safekeeping and issuer-related services. Financial dealers, including dealers in digital assets, are licensed under the Financial Dealers Licensing Act, which requires a local office and a resident manager or director.
Labuan Financial Services Authority (Labuan FSA)
A money broking licence may cover facilitating trades in digital assets that are not securities; in that case paid-up capital of RM 1.5 million is required. Services are limited to institutional and high-net-worth clients, and the licensee must have an office in Labuan.
FINTRAC; Revenu Québec (Québec)
Money services businesses, including virtual currency dealers, register with FINTRAC; this is a registration, not a licence, and it lapses unless renewed every two years. Foreign businesses serving clients in Canada must also register, and Québec additionally requires a provincial licence.
FinCEN; state financial regulators
Money services businesses register with FinCEN within 180 days of being established and renew every two years; registration is not a licence. Money transmission is licensed at state level, and 31 states have adopted the model Money Transmission Modernization Act in full or in part.
We list only regimes we have verified. Other jurisdictions are assessed on request.
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