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Crypto License in Gibraltar

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Gofaizen & Sherle helps businesses storing or transferring customer value using distributed ledger technology (DLT). We assess your activities, prepare applications and help with regulator responses. The Gibraltar Financial Services Commission (GFSC) decides which services your company may provide under its application.

Service Snapshot

  1. Regulator and Permission

    GFSC Part 7 permission for applicable DLT or virtual asset arrangements activities

  2. Service and Fees

    Application preparation and follow-up; agreed professional fees; initial GFSC application is £45,000

  3. Capital and Office

    Risk-based capital; Gibraltar registration and office; key business decisions made there

  4. Review Time and Ongoing Duties

    GFSC targets nine months for DLT review, subject to conditions. Allow preparation and banking time, and maintain governance and financial-crime controls.

Is This Route Right for Your Project?

Consider this route for DLT storage or transmission of others’ value in or from Gibraltar. Identify who controls customer assets and check target-market rules.

Own-account trading without client service and pure software or research can fall outside. Exchange arrangements can require permission without custody.

DLT Permission and VAA Permission

ActivityRegulatory OutputAuthorityKey RequirementLimitation
Store or transmit others’ value using DLTDLT Part 7 permissionGFSCMeet applicable principlesExclusions apply
Exchange or arrange exchanges of virtual assets with money or other virtual assetsVAA Part 7 permissionGFSCActivity-specific safeguardsPermission may be required without custody

You may need additional permissions if your services involve securities, payments or electronic money.

Activities and Business Models

  • For custodial exchanges and wallets, check who controls customer assets and holds the keys.
  • For custody and transfer services, identify who stores or moves customer value.
  • Noncustodial brokers may need VAA permission when arranging over-the-counter (OTC) exchanges.
  • For token issuance, lending, NFTs and stablecoins, assess product functions and applicable financial-instrument or electronic-money rules.

Regulation can still apply to decentralized services.

What Gofaizen & Sherle Handles

Gofaizen & Sherle assesses the route, supports corporate setup and prepares the business plan and application. Work includes governance and AML policies, submission and GFSC responses.

You provide accurate ownership, personal, financial and technical inputs. Local providers perform appointed setup tasks; GFSC assesses the application. Agree banking and ongoing compliance tasks.

Fees and Capital Resources

Work or CostProfessional FeeOfficial FeeThird-Party CostDependency
Application preparation and filingAgreed for included tasks£45,000 initial DLT/VAA applicationSetup costs as applicableActivities and permissions
Annual supervisionOngoing support agreed separatelyG1 calculation below; £4,017 AML supervisionCompliance and audit costs as applicableActivity and volume
Company and office setupConfirm included tasksApplicable setup chargesOffice and local-provider costsRequired arrangements

The annual G1 fee combines £12,254, 0.1% of relevant trade value (capped at £92,700) and an additional £28,183. Trade value means DLT reported volume or VAA trades arranged. Additional permissions and approved-person charges can add costs.

The company must also have enough financial resources to cover its risks and pay its debts if it stops operating. These funds belong to the company and are not a fee paid to the regulator.

There is no £50,000 minimum that applies to every provider.

The Team Behind the Application

Mark Gofaizen
Mark Gofaizen
Senior Partner, Head of Consulting
Maksim Gasanbekov
Maksim Gasanbekov
Partner, Head of Sales (Crypto and Blockchain)

The Application Process

The Gibraltar crypto licensing process begins with an assessment, local setup and client inputs.

Step 1 Stage 1: you and Gofaizen & Sherle prepare the tailored business plan, capital proposal and key-person information, with controller and funding documents.
Step 2 Stage 2: explain how your business handles risk, technology, governance, cybersecurity, outsourcing and financial-crime controls.
Step 3 Stage 3: finalize conduct, financial resources and policy documents, including banking and audit arrangements and signed regulated-person forms.

GFSC allows progression when satisfied, may request information and decides authorisation. A post-permission onsite visit follows. Launch requires permission and operational readiness.

What to Prepare

To assess your plans and identify the requirements that apply, provide the following information and documents:

  • Owners, ultimate beneficial owners (UBOs), directors, managers and key persons; founder residence
  • Products, customers, target markets, custody or control arrangements and revenue model
  • Fiat and asset flows, counterparties and expected volumes
  • Entity’s details, ownership chart and sources of wealth and funds
  • Business plan, financial forecasts, policies, technical and security documents, and previous applications.
  • Your office, capital and governance plans, including who is responsible for money-laundering reporting.
GFSC can require further documents.

Timeline

GFSC’s best-endeavoured DLT review target is nine months: five for Stage 1, two for Stage 2 and two for Stage 3. Work starts after the required fee payment and information arrival, and may pause for further information.

Client information and setup, consultant preparation and bank account opening might take longer time. The DLT target is neither a VAA timeline nor a launch promise.

Which Rules Apply

Part 7 permission covers relevant activities in or from Gibraltar under the Financial Services Act 2019 and Financial Services (DLT Providers and VAA Providers) Regulations 2020.
DLT covers business use of distributed ledger technology to store or transmit value belonging to others.
VAA covers exchanging virtual assets for money or other virtual assets, including arranging these exchanges. Check whether any exclusions or other financial-services rules apply. GFSC supervises both categories. VAA authorization now goes beyond AML registration.

DLT providers must follow ten regulatory principles proportionate to their risks. The Proceeds of Crime Act 2015 and applicable GFSC guidance provide the basis for financial-crime controls. Your permission lists permitted activities. It does not give unrestricted foreign-market access.

Current Regulatory Status

RegimeAuthorityCurrent StatusSourceApplicant Action
DLTGFSCPart 7 permission2020 RegulationsAssess customer-value activities
VAAGFSCPart 7 permission; inclusion effective 27 October 20252020 RegulationsAssess exchange arrangements
Provider statusGFSCLive register with linked permissionsDLT Providers RegisterCheck firm and permitted services

Duties After Approval

Providers must maintain governance and adequate resources, manage risks, protect customers, keep systems secure and remain resilient. The ten DLT principles also address honesty, fair treatment and market integrity. AML/CFT/CPF stands for anti-money laundering, counter-terrorist financing and counter-proliferation financing. Match controls, monitoring and suspicious-transaction reporting to your risks. For VAA services, tailor safeguards to how you hold assets and handle client money.

Plan for recordkeeping, reports, required audits and annual fees. Tell GFSC promptly about events affecting compliance with the principles. Follow the applicable procedure for material changes and changes to controllers or key persons. Notify the GFSC at least 30 days before declaring dividends or deciding to distribute capital. The company may make the payment only if the GFSC has not objected.

Permissions Before Launch

Get the required permissions before you begin regulated activities. Breaching regulatory rules can lead to administrative penalties. GFSC can also prohibit an unfit person from specified functions.

Banking and Operational Setup

A license does not guarantee acceptance by a bank, electronic-money institution (EMI) or payment-service provider (PSP). Each institution assesses risk differently, so allow time for its account-opening process.

Prepare ownership, funds or wealth documents, flows, markets, counterparties, volumes and compliance controls.

Taxes on Business Income

Since 1 July 2024, the standard corporation tax rate for most companies has been 15%. Business profits or gains are taxable if they accrue in or are derived from Gibraltar. Income is not automatically exempt because your customers are overseas. Check your structure’s income source and tax residence. Consider individual and transaction taxes separately.

Compare Relevant Regulatory Routes

RegimeRegulatorMarket ScopeKey RequirementLimitation
Gibraltar DLTGFSCActivities in or from GibraltarLocal office and managementNo MiCA passport or automatic UK access
EU MiCA CASPNational authorityUnion cross-border servicesEU office, effective management and Article 65 notificationRequires EU authorisation
Georgia VASPNational Bank of GeorgiaNational virtual-asset servicesRegistrationNo EU passport
UK cryptoFCAUK activities and consumer promotionsAssess AML, promotions and regulated-token rulesFuture FSMA crypto rules start 25 October 2027

Frequently Asked Questions

Who needs DLT permission?

Businesses using DLT to store or transmit others’ value in or from Gibraltar, subject to applicable exclusions.

How do I apply to GFSC?

Discuss the model, then submit the fee and Stage 1 documents. GFSC controls subsequent progression.

Is VAA permission the same as a VASP registration?

No. VASP is a general category. Gibraltar’s DLT and VAA permissions are activity-specific.

What determines the total cost?

Budget for official fees, professional work, setup and operations. Additional permissions can increase fees.

Is there a fixed capital minimum?

DLT capital is risk-based and must cover an orderly, solvent wind-down. Fees are separate.

Do I need a Gibraltar office?

Yes. GFSC requires key business decisions and ongoing management to take place in the Gibraltar office.

What AML controls are required?

Maintain risk-based customer checks, monitoring, suspicious-transaction reporting, records and clear compliance responsibilities.

How long does the DLT review take?

GFSC targets nine months for three stages, conditional on complete, timely inputs. Preparation and mobilization may add time.

Does Gibraltar permission provide MiCA passporting?

No. Assess EU access separately under MiCA. Gibraltar permission confers no EU passport.

Does permission guarantee a bank account?

No. Banks, EMIs and PSPs assess ownership, funding, flows and controls separately.

Are profits from overseas customers tax-free?

Not automatically. Income source determines tax treatment. Overseas customers alone do not establish exemption.

Can I launch before authorization?

Obtain permission and meet its conditions first. GFSC may restrict operations during mobilization.

Mark Gofaizen
Mark Gofaizen
Senior Partner, Head of Consulting
Maksim Gasanbekov
Maksim Gasanbekov
Partner, Head of Sales (Crypto and Blockchain)
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