Licence types · Digital assets

Virtual asset service provider (VASP)

Registration or licensing for virtual-asset businesses outside MiCA (e.g. Switzerland, UAE, UK, Singapore).

VASP regimes differ widely. Some are AML registrations (e.g. UK FCA cryptoasset registration, Swiss SRO affiliation) while others are full licensing regimes (e.g. Dubai VARA, Singapore DPT services under the PSA, Hong Kong SFC VATP).

By jurisdiction

🇨🇭 Switzerland

Swiss crypto / VASP models (via SRO or FINMA licence)

Regulator: Self-regulatory organisations recognised by FINMA (SRO)
Permitted activities: Crypto exchange and transfer services generally qualify as financial intermediation requiring SRO affiliation; custody models differ depending on whether assets are segregated and attributable to clients.
Minimum capital: Depends on route: none under AMLA; FinTech or banking licence where client crypto-assets are held collectively without segregation.
Ownership, management & substance: Swiss operational presence; travel-rule compliant transfer processes (FINMA Guidance 02/2019).
Application procedure: Determine qualification with legal counsel; apply to SRO or FINMA accordingly.
Government fees: Verification required
Indicative timeline: No reliable published estimate
Limitations: Operating a trading facility for DLT securities requires separate FINMA authorisation under the DLT framework.
Legal basis: AMLA; FINMA Guidance 02/2019; DLT Act amendments

🇬🇧 United Kingdom

FCA cryptoasset registration (MLRs)

Regulator: Financial Conduct Authority (FCA)
Permitted activities: Cryptoasset exchange and custodian wallet provision (AML registration).
Minimum capital: No prudential capital under MLR registration.
Ownership, management & substance: UK presence expected.
Application procedure: Registration application to FCA under the Money Laundering Regulations.
Government fees: Verification required
Indicative timeline: No reliable published estimate
Limitations: AML registration only; financial promotions regime applies; a full cryptoasset authorisation regime is being introduced.
Legal basis: MLRs 2017

🇦🇪 United Arab Emirates

Dubai VARA VASP licence

Regulator: Virtual Assets Regulatory Authority (VARA)
Permitted activities: Virtual asset activities (exchange, broker-dealer, custody, transfer, lending, management) in Dubai excluding DIFC.
Minimum capital: Set per activity by VARA rulebooks — Verification required.
Ownership, management & substance: Licensed entity in Dubai with local presence.
Application procedure: VARA licensing process after DET initial approval.
Government fees: Verification required
Indicative timeline: No reliable published estimate
Limitations: Does not cover DIFC (DFSA) or ADGM (FSRA).
Legal basis: Dubai Law No. 4 of 2022

🇸🇬 Singapore

Digital payment token service (PSA)

Regulator: Monetary Authority of Singapore (MAS)
Permitted activities: Dealing in or facilitating exchange of DPTs, custody and transfer.
Minimum capital: Base capital per licence class — Verification required.
Ownership, management & substance: Singapore presence; restrictions on serving only overseas customers under FSMA.
Application procedure: Application to MAS.
Government fees: Verification required
Indicative timeline: No reliable published estimate
Limitations: Stringent; MAS has limited new DPT licences.
Legal basis: Payment Services Act 2019; FSMA 2022

🇭🇰 Hong Kong

SFC virtual asset trading platform licence

Regulator: Securities and Futures Commission (SFC)
Permitted activities: Operating a centralised virtual asset exchange.
Minimum capital: Verification required
Ownership, management & substance: Hong Kong presence; responsible officers.
Application procedure: Application to SFC.
Government fees: Verification required
Indicative timeline: No reliable published estimate
Limitations: —
Legal basis: AMLO Part 5B; SFO

🇦🇺 Australia

AUSTRAC digital currency exchange registration

Regulator: AUSTRAC (AUSTRAC)
Permitted activities: Exchange between digital currency and money.
Minimum capital: No prudential capital under registration.
Ownership, management & substance: Australian registration.
Application procedure: Register with AUSTRAC; AFSL may additionally be required for financial products.
Government fees: Verification required
Indicative timeline: No reliable published estimate
Limitations: Digital asset platform licensing reform in progress.
Legal basis: AML/CTF Act 2006