Crypto License

Who This Service Fits

Exchange, custody, and transfer operators can seek application support. Brokerage, advice, portfolio management, and payment processing need individual assessment. Token issuance and derivatives require separate analysis. Сryptocurrency use alone does not require licensing.

Regulatory Routes

Route	Authority	Covered activities	Market reach	Key limitation
Canada	FINTRAC, Bank of Canada	Crypto exchange/OTC and payments; fiat exchange, custody and transfers	Canadian and overseas customers, where permitted	AML registration grants no securities or provincial permissions
Montana (US)	FinCEN	Crypto exchange/OTC, custody and payments; fiat exchange, custody and payments	US and overseas customers, where permitted	Montana requires no money-transmitter license. Federal duties apply. FinCEN grants no other-state permissions
Switzerland	Self-regulatory organization / FINMA	Montana’s activities, plus crypto asset management, loans using borrowed funds and utility token issuance	Swiss and overseas customers, where permitted	Membership grants no general FINMA authorization
Costa Rica	SUGEF	Crypto exchange/OTC, custody, asset management, payments, derivatives, loans using borrowed funds, security token issuance/trading and utility token issuance; fiat custody	Costa Rican and overseas customers, where permitted	AML registration grants no operating permit
Panama	SMV (securities) / SBP (banking/remittance AML)	Same activities as Costa Rica	Panamanian and overseas customers, where permitted	Incorporation grants no financial license

Types of Crypto Services and Who Needs Them

Required permissions depend on the service, jurisdiction, and whether you handle customer assets. Operating without custody does not automatically remove licensing duties. A business combining several services may need several permissions, rather than one license covering every activity.

Type/service	What it covers	Who needs it
Brokerage	Arranging client trades or routing orders	Brokers and liquidity aggregators
Portfolio management	Making investment decisions under a client mandate	Crypto asset managers
Advice	Giving personalized crypto investment recommendations	Investment advisers
Exchange	Converting crypto into fiat or other crypto	Online exchangers and crypto ATMs
Custody	Safeguarding customer assets or private keys	Custodial wallet providers and exchanges
Transfers	Moving crypto for customers	Crypto transfer providers
Payment processing	Accepting and settling crypto payments	Merchants, gateways, and payment processors
Spot trading platform	Matching multiple buyers’ and sellers’ orders	Spot exchange operators
Derivatives	Offering futures, options, or perpetual contracts	Derivatives platforms
Token issuance	Offering utility, stablecoin, or security tokens	Token issuers

Derivatives and token issuance follow the rules applicable to the instrument and jurisdiction. They may require permissions beyond crypto service authorization.

Pricing Factors

The quote should separate professional fees, government fees, third-party expenses, and ongoing costs. Required capital or other financial safeguards are separate from the service price. Agree what the selected service includes and excludes.

Information to Prepare

To assess ownership and structure, provide:

• founders
• ultimate owners
• directors
• existing entities
• funding sources.

Products, founder/customer countries, fiat/asset flows, and volumes help identify permissions. Technology, policies, the business plan, and prior filings show remaining work.

Timing Dependencies

Client evidence, company setup, local presence, and documentation affect preparation; some work can overlap. Authority review and corrections have a separate timetable. Banking follows the provider’s review.

Global Regulatory Framework

No license grants worldwide permission. Local law determines market reach. Payments, securities, or issuance can need additional permissions.

For example, BCR registration comes before the relevant SSF procedures. A registration receipt alone does not authorize operation.

Current Regulatory Status

Canada requires AML registration for money services businesses (MSBs), including foreign MSBs targeting and serving Canada.
In Montana, federal MSB registration applies, while the state does not require a money-transmitter license.
Costa Rica also has a statutory AML registration requirement.
Panama’s financial permissions depend on the services provided.
El Salvador has separate regimes for digital asset and Bitcoin service providers. Digital asset service providers (DASPs) require registration and authorization to operate. Bitcoin service providers (BSPs) are subject to Bitcoin registration and supervision under a distinct regime.
In the EU, crypto-asset service providers need authorization under the Markets in Crypto-Assets Regulation (MiCA). The transition period has ended.
Switzerland uses affiliation with a self-regulatory organization for AML supervision.

Ongoing Responsibilities

Canada
The MSB/FMSB must perform risk-based ongoing monitoring of established customer relationships under Canada’s anti-money laundering law (PCMLTFA) and regulations.

Switzerland
The intermediary must identify customers and beneficial owners when establishing relationships under the Anti-Money Laundering Act (AMLA).

Costa Rica
Covered providers must report suspicious and attempted transactions confidentially, without delay, to UIF/ICD under Law 7786 Article 15 quater, added by Law 10961.

Montana (US)
The MSB’s designated compliance person oversees its continuing written AML program under the BSA and 31 CFR 1022.210.

Panama
Where regulated remittances are included, the company must maintain AML controls and submit required operational reports under Law 23/2015 and remittance-sector rules.

Banking Readiness

Providers assess status, ultimate owners, funding sources, flows, countries, counterparties, and volumes. Gofaizen & Sherle prepares agreed evidence. The bank or payment provider decides whether to accept the business.

Tax Considerations

Compare residence and income-source rules, corporate tax, value-added/goods-and-services taxes, local operations, payroll, and token/transaction treatment. Check each exemption’s conditions against your business before relying on it.

Compare Regulatory Routes

Route	Market Fit	Regulator	Local Presence	Timing	Cost Drivers	Limitation
Canada MSB/FMSB	Exchange/transfers	FINTRAC	Domestic/foreign routes	Register before operation	Controls	Securities/provincial permissions separate
El Salvador DASP	Digital assets	CNAD	Assess structure	Review/queries	Documents	Not BSP
El Salvador BSP	Bitcoin	BCR/SSF	Assess setup	BCR before SSF	Procedures	Receipt insufficient
Switzerland SRO	Financial intermediation	SRO/FINMA	Model-specific	Affiliation assessment	Diligence	Further licenses possible
Costa Rica registration	Covered VASPs	SUGEF	Confirm requirements	Confirm procedure	AML controls	Registration only
Montana (US) MSB	Transmission	FinCEN	Model-specific	Federal filing	Compliance	Other states separate
Panama activity-specific	Financial services	SMV/SBP	Sector-specific	Sector procedure	Applicable controls	No incorporation-based permission
EU CASP	EU services	National authority	EU office/management; at least one EU-resident director	Review	Safeguards	Instrument limits