Planning an exchange, custody, or transfer service? Gofaizen & Sherle helps identify the permissions you need and prepare your application. “Crypto license” is a market term. The actual permission depends on what your business does and where its customers are.
Service Snapshot
Step
Route
Chosen by activity and jurisdiction
Step
Authority
Determined by the route
Step
Activities
Service-specific permission scope
Step
Entity
Structure and local presence
Step
Timing
Preparation plus external review
Step
Capital
Route-specific financial safeguards
Step
Compliance
Continuing operating duties
Step
Banking
Separately scoped preparation
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. Cryptocurrency 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
Derivatives and token issuance follow the rules applicable to the instrument and jurisdiction. They may require permissions beyond crypto service authorization.
Our Scope of Work
Gofaizen & Sherle provides
jurisdiction assessment
activity mapping
corporate coordination
application documents
AML and CFT
governance
agreed regulator communication
ongoing support.
You supply accurate ownership and operating evidence. Authorities decide applications.
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.
Application Process
Step1Gofaizen & Sherle and you map activities and markets.
Step2Agree the route and work scope before setup decisions.
Step3You provide evidence. Gofaizen & Sherle coordinates setup and documentation.
Step4Submit and answer authority queries.
Step5Await necessary permissions and resolve conditions. Unanswered queries remain pending.
Step6Agree ongoing responsibilities and operational setup.
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
Functions decide. BCR excludes certain noncustodial technology providers; customer custody or transmission changes the assessment. This is not a worldwide software exemption.
Can an existing registration cover a new service?
Not automatically. Assess added custody or issuance against your existing scope and the applicable activity rules before offering it.
What if our target market changes?
Supply revised customer countries and marketing plans before expansion.
What if we already have a company?
Check whether it meets the chosen route’s incorporation, management, and local-presence conditions before committing to restructuring.
What if our operating costs increase?
For EU CASPs, higher fixed overheads can change required financial safeguards. Update projections and recalculate.
What happens after a regulator query?
Allocate evidence between your team and Gofaizen & Sherle, respond, and await resolution or further questions.
Does offshore mean no local team?
No. Seychelles requires a resident director and staffed office. Check your proposed arrangements against that regime.
What if a bank declines the application?
Review its stated reason and address actual evidence gaps within the agreed scope. Another provider’s acceptance remains its decision.
What tax information should we collect?
Gather residence facts, transaction types, and fee flows for individual assessment, including where business decisions and activities occur.
What changes need attention after approval?
Assign someone to check applicable update and notification duties when ownership, services, or operations change. Deadlines depend on the route.
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