Licensing Hub

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We track licensing pathways for crypto, AI, and digital asset businesses across 104 jurisdictions. Each guide covers the live regulator, the realistic timeline, the actual cost, and the common ways founders get tripped up.

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Coverage

Every jurisdiction we cover, by region

Updated as regulations evolve. Pick a market to see the regulator, available licence types, typical timelines, and what we've learned from running engagements there.

Americas

14 jurisdictions

Argentina

Argentina licenses virtual asset service providers under Law 27,739, with the CNV running the PSAV register and the UIF enforcing AML obligations.

Regulator: Comisiรณn Nacional de Valores (CNV)Timeline: CNV PSAV registration is substantive; transitional deadlines under RG 1058/2025 have passed, so registration and UIF filings are now active.
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Bermuda

Bermuda licenses digital asset business under the Digital Asset Business Act 2018 in Class F, M or T, supervised by the Bermuda Monetary Authority.

Regulator: Bermuda Monetary Authority (BMA)Timeline: DAB licence: BMA reviews once the application package and Schedule 1 minimum criteria are satisfied. No statutory deemed-decision period.
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Brazil

Brazil licenses virtual asset service providers under Law 14,478/2022 and BCB Resolutions 519-521/2025, with the Banco Central do Brasil as supervisor.

Regulator: Banco Central do Brasil (BCB)Timeline: BCB authorisation runs up to 1,080 days for active SPSAVs (360 plus 720 in two phases) and 720 days for non-active SPSAVs.
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British Virgin Islands

The BVI regulates crypto businesses under the Virtual Assets Service Providers Act 2022, requiring registration with the Financial Services Commission (FSC).

Regulator: Financial Services Commission (FSC)Timeline: FSC virtual asset service provider applications run on substantive review; no statutory deemed-decision period.
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Canada

Canada has no single crypto licence. Digital-asset businesses face FINTRAC MSB registration, CSA/CIRO securities oversight and the new federal Stablecoin Act.

Regulator: FINTRAC, CSA / provincial securities regulators, and Bank of CanadaTimeline: FINTRAC MSB registration is pre-operations with no fixed clock. CTP securities registration runs months and varies by province.
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Cayman Islands

The Cayman Islands runs a dedicated VASP regime under the Virtual Asset (Service Providers) Act, with CIMA licensing custody and trading platforms.

Regulator: Cayman Islands Monetary Authority (CIMA)Timeline: Phase Two transition applicants had 90 days from 2025-04-01 to apply. New applications get substantive CIMA review with no statutory clock.
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Chile

Chile regulates cryptoasset business under the Fintec Law (No. 21,521) and CMF NCG 502, with CMF authorisation and UAF supervising AML obligations.

Regulator: Comisiรณn para el Mercado Financiero (CMF)Timeline: CMF has a six-month review period for service authorisation, suspended while the applicant cures deficiencies.
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Colombia

Colombia has no general VASP licence. Providers report to the UIAF under Resolution 314/2021, and the SFC has not authorised supervised entities to custody crypto.

Regulator: Superintendencia Financiera de Colombia (SFC), UIAF, Superintendencia de Sociedades, Banco de la Repรบblica and DIANTimeline: UIAF SIREL reporting is operative: suspicious operations filed immediately, monthly reports within 20 calendar days of month-end.
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Curaรงao

Curaรงao completed a comprehensive gambling reform in December 2024. The LOK replaced the old master-license system. The CGA (formerly GCB) issues direct B2C, B2B and Nonprofit licences. No domestic crypto licensing regime.

Regulator: Curaรงao Gaming Authority (CGA)Timeline: CGA B2C and B2B licences: typically 8 weeks per phase (corporate integrity and operational). Provisional licence valid for 6 months extendable. Indefinite licence validity once granted.
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El Salvador

Latin America's most permissive crypto regime. CNAD licenses DASPs and BSPs under LEAD 2023 with 0% corporate tax on digital-asset activities. LNB issues unified gambling licences under the 2021 Organic Law.

Regulator: National Commission of Digital Assets (CNAD)Timeline: CNAD DASP licence: 3โ€“6 months from incorporation to authorisation. LNB gambling licence: 15 business days for initial business establishment; up to 10 years validity.
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Mexico

Mexico has no general VASP licence. Banxico Circular 4/2019 limits banks and fintechs to internal crypto use, while non-financial providers fall under LFPIORPI AML rules.

Regulator: Banco de Mรฉxico, CNBV, SHCP/SAT/UIFTimeline: SAT/SPPLD vulnerable-activity registration is required before the first Aviso. Avisos are filed by the 17th of the following month.
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Panama

Panama has no cryptoasset-specific statute. A 2021 bill was voided by the Supreme Court, leaving no special crypto legislation in force.

Regulator: Superintendencia del Mercado de Valores (SMV)Timeline: No bespoke virtual asset licensing regime is in force; existing financial and AML rules apply on a case-by-case basis.
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The Bahamas

The Bahamas operates a dedicated digital asset regime under the DARE Act 2024, administered by the Securities Commission of The Bahamas (SCB).

Regulator: Securities Commission of The Bahamas (SCB)Timeline: DARE digital asset registration: substantive SCB review with no statutory deemed-decision period. Renewal falls due by 31 January each year.
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United States

The United States has no single crypto licence. Providers face FinCEN MSB, SEC, CFTC and OFAC rules, the GENIUS Act stablecoin regime, plus state licences like the NY BitLicense.

Regulator: FinCEN, SEC, CFTC, OFAC, federal banking agencies, and state regulators (NYDFS, California DFPI, others)Timeline: FinCEN MSB is a notice filing; SEC and CFTC routes typically run 6 to 18 months. NY BitLicense and California DFAL are substantive.
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EU + EEA

30 jurisdictions

Austria

Full MiCA jurisdiction supervised by the Austrian Financial Market Authority (FMA). The Oesterreichische Nationalbank handles certain token, banking and payment-system matters.

Regulator: Austrian Financial Market Authority (FMA)Timeline: FMA confirms receipt in 5 working days, checks completeness in 25, and decides in 40 to 60 working days; in practice several months. Pre-MiCA continuation ended 31 December 2025.
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Belgium

Full MiCA jurisdiction. The FSMA licenses stand-alone crypto-asset service providers, while the National Bank of Belgium covers banks, e-money and payment institutions.

Regulator: FSMATimeline: FSMA decides CASP applications under Article 63; transitional period for cross-border legacy CASPs ends 1 July 2026 or upon authorisation, whichever comes first.
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Bulgaria

Full MiCA jurisdiction under the Bulgarian Markets in Crypto-Assets Act. The FSC licenses stand-alone CASPs and the Bulgarian National Bank covers e-money tokens.

Regulator: Financial Supervision Commission (FSC)Timeline: FSC review of CASP applications takes 4 to 5 months and may extend if incomplete; transitional period for NRA-registered providers ends 1 July 2026.
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Croatia

Full MiCA jurisdiction. HANFA is the main authority for ordinary CASPs, and the Croatian National Bank handles asset-referenced and e-money token matters.

Regulator: HANFATimeline: HANFA decides CASP applications filed on the EU standard form; legacy VASP transition ends 1 July 2026.
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Cyprus

Full MiCA jurisdiction. CySEC licenses stand-alone CASPs and Article 60 notifications, while the Central Bank of Cyprus covers credit, e-money and payment institutions.

Regulator: Cyprus Securities and Exchange Commission (CySEC)Timeline: CySEC decides CASP applications under Article 63; national-regime applications were due by 27 February 2026 and transitional period ends 1 July 2026.
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Czech Republic

Full MiCA jurisdiction. The Czech National Bank is the sole competent authority, and the former unqualified-trade route for crypto services has ended.

Regulator: Czech National Bank (CNB)Timeline: CNB decides CASP applications; first six authorisations issued in February 2026 from 248 filings. Transitional providers may continue until 1 July 2026.
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Denmark

Full MiCA jurisdiction supervised by the Danish FSA (Finanstilsynet). Not a light-touch regime: Danish presence, local management and operational control are central licensing issues.

Regulator: Danish Financial Supervisory Authority (Finanstilsynet)Timeline: Finanstilsynet decides CASP applications filed via Virk; Article 60 notifications go in at least 40 working days before service starts. Transition ends before 1 July 2026.
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Estonia

Full MiCA jurisdiction under the Estonian Market in Crypto-Assets Act. Finantsinspektsioon licenses CASPs, and the former FIU VASP regime is transitional only.

Regulator: Estonian Financial Supervision Authority (EFSA)Timeline: Finantsinspektsioon runs a 25 working day completeness check and 40 working day substantive review, pausable up to 20. Transition ends 1 July 2026.
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Finland

Full MiCA jurisdiction supervised by the Finnish Financial Supervisory Authority (FIN-FSA). The former Finnish virtual-currency provider registration regime has been repealed.

Regulator: Finnish Financial Supervisory Authority (FIN-FSA)Timeline: FIN-FSA runs a 25 working day completeness check and 40 working day qualitative assessment, pausable up to 20. National transition ended 30 June 2025.
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France

Full MiCA jurisdiction. The AMF licenses standard CASPs, with the ACPR covering AML/CFT, sanctions and prudential matters. The former DASP regime is now transitional.

Regulator: Autoritรฉ des marchรฉs financiers (AMF)Timeline: AMF decides CASP applications with a binding ACPR opinion on AML controls; MiCA transition for legacy French DASPs ends 1 July 2026.
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Germany

Full MiCA jurisdiction supervised by BaFin under the German KMAG and Financial Market Digitalisation Act. The pre-MiCA German grandfathering period has expired.

Regulator: BaFinTimeline: BaFin decides CASP applications on the standard MiCA form and charges time-based fees; Article 60 notifications go in 40 working days ahead. Grandfathering expired 31 December 2025.
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Greece

Full MiCA jurisdiction under Greek Law 5193/2025. The HCMC licenses standard CASPs and the Bank of Greece covers credit, e-money, payment institutions and certain token matters.

Regulator: Hellenic Capital Market Commission (HCMC)Timeline: HCMC decides CASP applications with pre-application engagement; transition for providers registered before 27 December 2024 runs until 30 June 2026.
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Hungary

Full MiCA jurisdiction supervised by the Magyar Nemzeti Bank (MNB) under Act VII of 2024. A separate SZTFH conversion-validation regime applies to exchange services.

Regulator: Magyar Nemzeti Bank (MNB)Timeline: MNB decides CASP applications; Article 60 notifications go in at least 40 working days before service starts. National transition expired 1 July 2025.
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Iceland

Iceland regulates crypto activity as an AML matter. VASPs must register with the Central Bank of Iceland under the 2018 anti-money-laundering Act, not obtain a full financial licence.

Regulator: Central Bank of Iceland (FME)
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Ireland

Full MiCA jurisdiction supervised by the Central Bank of Ireland under the EU (Markets in Crypto-Assets) Regulations 2024. The former Irish VASP AML registration is not equivalent.

Regulator: Central Bank of IrelandTimeline: Central Bank of Ireland decides CASP applications via its Portal from 2 April 2026, after early engagement and a key facts document. Transition ended 30 December 2025.
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Italy

Full MiCA jurisdiction under Legislative Decree 129/2024. Dual-authority model: Consob authorises specialised CASPs after a Bank of Italy opinion. Transition backstop: 30 June 2026.

Regulator: CONSOB / Bank of ItalyTimeline: Specialised CASP applications go to Consob with Bank of Italy input. Article 60 notification at least 40 working days before service starts. Italian transition ends 30 June 2026.
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Latvia

Full MiCA jurisdiction supervised by Latvijas Banka, which is also the Latvian AML authority for CASPs. The former AML-supervised virtual-asset regime has expired.

Regulator: Latvijas BankaTimeline: CASP applications go to Latvijas Banka. Completeness check 25 working days; substantive review 40 working days. Application review fee EUR 2,500.
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Liechtenstein

Full MiCA jurisdiction via the EEA-MiCA-Implementation Act, in force 1 February 2025. The Financial Market Authority (FMA) is sole competent authority for licensing and supervision.

Regulator: Financial Market Authority (FMA)Timeline: TT service provider registration with the FMA runs three to six months; MiCA CASP authorisation decisions within five months once EEA incorporation completes.
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Lithuania

Full MiCA jurisdiction supervised by the Bank of Lithuania, with FNTT covering AML. A high-substance regime: empty shell companies will not be tolerated.

Regulator: Bank of LithuaniaTimeline: CASP applications go to the Bank of Lithuania. Completeness check 25 business days; substantive assessment 40 business days. Lithuanian transition ended 31 December 2025.
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Luxembourg

Full MiCA jurisdiction. CSSF is the competent authority for CASP authorisation, Article 60 notifications, MiCA supervision and Transfer of Funds Regulation enforcement.

Regulator: Commission de Surveillance du Secteur Financier (CSSF)Timeline: CASP applications go to the CSSF. Decisions within five months; MiCA transitional period ends 1 July 2026.
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Malta

Full MiCA jurisdiction. MFSA is the competent authority for CASP authorisation and supervision; FIAU handles AML/CFT. The legacy VFA framework is now transitional only.

Regulator: Malta Financial Services Authority (MFSA)Timeline: CASP applications go to the MFSA. Decisions within five months; MiCA transitional period ends 1 July 2026.
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Netherlands

Full MiCA jurisdiction. AFM is the main regulator for CASP authorisation; DNB handles prudential supervision and ART/EMT issuers. The Dutch transitional regime has expired.

Regulator: Authority for the Financial Markets (AFM)Timeline: CASP applications go to the AFM with DNB input. Decisions within five months; MiCA transitional period ends 1 July 2026.
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Norway

Full MiCA jurisdiction under the Kryptoeiendelsloven, in force 1 July 2025. Finanstilsynet supervises, with a transitional window for registered providers until 30 December 2025.

Regulator: FinanstilsynetTimeline: CASP applications go to Finanstilsynet; decisions within five months once MiCA enters Norwegian law via EEA incorporation, expected during 2026.
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Poland

Polish MiCA implementation is incomplete. KNF has not been formally designated as competent authority for CASPs. Providers needing an EU licence now should look elsewhere.

Regulator: Polish Financial Supervision Authority (KNF)Timeline: CASP applications go to the KNF. Decisions within five months; MiCA transitional period ended 30 June 2025.
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Portugal

Full MiCA jurisdiction with a dual-authority model. Banco de Portugal leads on CASPs, prudential matters, ARTs and EMTs; CMVM covers offers, market abuse and conduct rules.

Regulator: Comissรฃo do Mercado de Valores Mobiliรกrios (CMVM)Timeline: CASP applications go to the CMVM with Banco de Portugal input. Decisions within five months; MiCA transitional period ends 30 June 2026.
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Romania

Romanian MiCA implementation is not yet operational. ESMA lists Romania as 'to be announced'; a draft ordinance would split competence between ASF and BNR but is not yet law.

Regulator: Financial Supervisory Authority (ASF)Timeline: CASP applications go to the ASF. Decisions within five months; MiCA transitional period ends 1 July 2026.
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Slovakia

Full MiCA jurisdiction. The National Bank of Slovakia (NBS) is the competent authority for CASP authorisation, Article 60 notifications and supervision. High-substance regime.

Regulator: National Bank of Slovakia (NBS)Timeline: CASP applications go to Nรกrodnรก banka Slovenska. Decisions within five months; MiCA transitional period ends 1 July 2026.
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Slovenia

Full MiCA jurisdiction with a split-authority model. ATVP authorises and supervises CASPs; Banka Slovenije handles e-money tokens and related EMI services. Transition has expired.

Regulator: Securities Market Agency (ATVP)Timeline: CASP applications go to the ATVP; Banka Slovenije handles EMT notifications. Slovenian MiCA transition expired 1 July 2025.
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Spain

Full MiCA jurisdiction with a dual-authority model. CNMV authorises and supervises CASPs (Titles II, V, VI); Banco de Espaรฑa covers ARTs, EMTs and PSD2 overlap (Titles III, IV).

Regulator: Comisiรณn Nacional del Mercado de Valores (CNMV)Timeline: CASP applications go to the CNMV with Banco de Espaรฑa input. Decisions within five months; MiCA transitional period ends 1 July 2026.
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Sweden

Full MiCA jurisdiction supervised by Finansinspektionen (FI). Legacy transition is closed to late entrants; only pre-MiCA providers who applied before 1 October 2025 may continue.

Regulator: Finansinspektionen (FI)Timeline: CASP applications go to Finansinspektionen. FI decides within 40 working days of a complete file. Swedish transition ended 30 September 2025.
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Other Europe

17 jurisdictions

Albania

Albania has one of the region's earliest dedicated crypto frameworks โ€” Law No. 66/2020 on Financial Markets Based on Distributed Ledger Technology (in force 1 September 2020), with five licence types issued by AFSA together with NAIS/AKSHI for technology certification. Payments and e-money are regulated by the Bank of Albania under Law No. 55/2020 on Payment Services (PSD2 transposition; open banking live from November 2024). Gambling was near-totally banned from 1 January 2019 under amendments to Law No. 155/2015 โ€” only 5-star-hotel casinos, TV bingo and the national lottery survived โ€” until Law No. 18/2024 reintroduced regulated online sports betting (max 10 licences).

Regulator: Albanian Financial Supervisory Authority (AFSA)Timeline: Crypto: AFSA licensing with a statutory review term of 60 days (suspended pending requested clarifications/documentation); NAIS reviews technology agreements. Payments/e-money: Bank of Albania licensing under Law No. 55/2020 (no single published statutory clock). Gambling: discretionary review by the License Commission; capped at ten online sports-betting licences.
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Armenia

Law on Crypto-Assets adopted 29 May 2025, in force 4 July 2025 โ€” MiCA-modelled. CBA is sole licensing regulator; minimum capital ~USD 30kโ€“530k. Gambling regulated by Ministry of Finance with State Revenue Committee supervision; land-based casinos restricted to four zones; consolidated Law on Regulation of Gambling Activity due to enter force by end-2026.

Regulator: Central Bank of Armenia (CBA)Timeline: Crypto: Law in force 4 July 2025; CBA Regulation 7/01 (Resolution 227-N) adopted 30 December 2025; pre-existing providers must be CBA-licensed by 31 January 2027. Gambling: current winning-games/lotteries framework in force; consolidated Law on Regulation of Gambling Activity due by end-2026.
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Azerbaijan

No crypto law in force as of May 2026; CBA co-authoring a draft virtual asset law (supervisory + sandbox), expected since end-2025 under the 2024โ€“2026 financial market development strategy. Gambling banned since 1998; narrow exceptions for Azerlotereya (state lottery) and Topaz (sports betting monopoly). January 2026 law permits casinos only on artificial islands in the Caspian Sea.

Regulator: Ministry of FinanceTimeline: Crypto: draft law in development since 2024; submission expected end-2025; not yet enacted as of May 2026. Gambling: casino licensing on Caspian artificial islands enabled by January 2026 law; no operators confirmed yet. Sports betting/lottery licences from MoF, typically 10-year national licence.
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Belarus

Crypto regulated through Decree No. 8 of 2017 (effective 2018) under the High-Tech Park regime, extended to 1 January 2049. Decree No. 19 of 16 January 2026 establishes licensed "crypto banks" โ€” HTP-resident joint-stock companies under dual National Bank / HTP regulation. Gambling regulated by the Ministry of Taxes and Duties under the Law on Gambling Business and Decree No. 305 of 2018; online gambling legal since April 2019.

Regulator: High-Tech Park Administration (HTP)Timeline: Crypto: HTP residency application + registration; crypto-bank registration with the National Bank under Decree No. 19 (2026); fiat-crypto exchange requires National Bank approval. Gambling: licence decision within 15 working days of a complete application; licence valid 10 years (with extension).
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Bosnia & Herzegovina

No dedicated crypto licence; virtual-asset and crypto-asset platforms became AML obligated entities under the state Law on the Prevention of Money Laundering and Financing of Terrorist Activities (Official Gazette of BiH No. 13/24, in force 28 February 2024). Payments and e-money are entity-level โ€” Republika Srpska's Law on Electronic Money (OG RS No. 1/24, applicable from 4 July 2024) supervised by ABRS. Gambling is entity-split: FBiH (2015), RS (2019, OG RS 22/19) and Brฤko District (2022).

Regulator: Financial Intelligence Department / SIPATimeline: No statutory single-window timeline because there is no unified licence. Company formation plus AML obligated-entity onboarding is the practical baseline; entity-level authorisations (RS e-money, RS/FBiH/Brฤko gambling) run on their own statutory clocks. Advisory estimates of "weeks to a few months" for crypto are unverified.
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Georgia

Three transparent tracks: NBG registers VASPs and licenses payment service providers; Revenue Service issues gambling licences under the 2005 Gambling Law, with a 5% GGR rate for foreign-only operators.

Regulator: National Bank of Georgia (NBG)Timeline: NBG VASP registration: 2โ€“4 months. Gambling licence: about 20 working days. Expedited 5-day processing available for online casino and online slots.
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Gibraltar

The Gibraltar Financial Services Commission authorises DLT and virtual asset providers under the Financial Services Act 2019. Part 7 permission requires local substance.

Regulator: Gibraltar Financial Services Commission (GFSC)Timeline: GFSC runs a three-stage application. POCA-registered providers must notify GFSC within 14 days of 27 October 2025 and apply for Part 7 permission within six months.
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Guernsey

The Guernsey Financial Services Commission licenses VASPs under Part III of the Lending, Credit and Finance regime. Activity is restricted to institutional and wholesale clients.

Regulator: Guernsey Financial Services Commission (GFSC)Timeline: GFSC publishes no VASP-specific timeframe. Timing depends on submission completeness, risk profile and proposed activities.
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Isle of Man

The Isle of Man Financial Services Authority registers VASPs under the Designated Businesses Act 2015 and AML/CFT Code. The regime is AML-focused, not full prudential licensing.

Regulator: Isle of Man Financial Services Authority (IOMFSA)Timeline: IOMFSA designated-business registration is required before any VASP activity. The Travel Rule Code came into force on 28 October 2024.
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Jersey

The Jersey Financial Services Commission registers VASPs as Schedule 2 businesses under its AML/CFT regime. Token issuance follows a separate JFSC consent process.

Regulator: Jersey Financial Services Commission (JFSC)Timeline: JFSC Schedule 2 / VASP registration is substantive, with fit-and-proper review and no statutory deemed-decision period.
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Moldova

No crypto law in force as of May 2026. First MiCA-aligned framework drafted by Ministry of Finance + BNM + CNPF + SPCSB, planned for enactment by end-2026. Gambling near-total state monopoly under Law 291/2016; only land-based casinos open to private operators (foreign ownership capped at 49%).

Regulator: National Bank of Moldova (BNM)Timeline: Crypto law: drafted; planned for enactment by end-2026. EMI / PSP licence under Law 114/2012: typically 6โ€“12 months with BNM. Casino licence: Public Services Agency procedures.
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Montenegro

Montenegro adopted its first-ever crypto-asset framework on 28 February 2025 as amendments to the AML law (a CASP registration model, not a standalone licence), with the Capital Market Authority as registry/regulator and the Central Bank (CBCG) in a supporting AML role. Payments and e-money are regulated by the CBCG under the PSD2-aligned Payment System Law (in force 8 October 2023); Montenegro joined SEPA in 2024โ€“2025. Gambling is legal and licensed under the New Games of Chance Act (adopted 31 July 2025), which replaced the concession model with an approval-based licensing regime; online gambling is available only to land-based special-games licensees. Montenegro unilaterally uses the euro.

Regulator: Capital Market Authority (CMA)Timeline: Crypto: CASP registration (not a traditional licence) โ€” reported ~2โ€“3 months if documentation is complete. Payments/e-money: CBCG authorisation under the Payment System Law (no single published statutory clock). Gambling: casino licence by Government (15-year term); betting/slot licences by the GCA; existing concession holders transition over up to 270 days (apply within 180 days).
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North Macedonia

North Macedonia has no dedicated crypto law; virtual assets sit in a legal grey zone, captured only by the AML/CFT Law (Official Gazette 4 July 2022, transposing EU Directive 2018/843), with MiCA-aligned draft legislation in development. Payments and e-money are regulated by the National Bank under the Law on Payment Services and Payment Systems (Official Gazette No. 90/2022, in force 1 January 2023, transposing PSD2/EMD2). Gambling is legal and licensed under the Law on Games of Chance and Entertainment Games (Ministry of Finance), with casinos, betting shops and slot clubs licensed and lottery/online a state monopoly; significant 7 February 2024 amendments tightened the regime.

Regulator: National Bank of the Republic of North Macedonia (NBRNM)Timeline: No crypto licensing timeline โ€” there is no crypto framework (AML duties only). Payments/e-money: NBRNM authorisation under the 2022 Law (no single published statutory clock). Gambling: Ministry of Finance decision on application within ~30 days (per practitioner guidance); licence terms typically 10โ€“15 years (casinos), shorter for some activities.
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Serbia

One of the few full crypto licensing regimes in Europe outside the EU/EEA. NBS licenses virtual-currency DASPs and the Securities Commission licenses digital-token DASPs under the Law on Digital Assets 2020. Gambling under the Games of Chance Administration.

Regulator: National Bank of Serbia (NBS)Timeline: NBS / Securities Commission decision: within 60 days of submission via the unified web portal. Games of Chance Administration approval: within 30 days for special games approvals.
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Switzerland

FINMA regulates crypto activity through technology-neutral financial-market laws. Routes include AMLA SRO affiliation, fintech licence, banking authorisation and DLT trading facility.

Regulator: Swiss Financial Market Supervisory Authority (FINMA)Timeline: FINMA authorisation duration depends on project complexity and application quality. SRO affiliation is the typical AMLA route for non-prudential crypto intermediaries.
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Ukraine

Ukraine has three licensing tracks: gambling under PlayCity, payments under the NBU, and crypto pending the second reading of Bill 10225-d. Each track has its own regulator.

Regulator: PlayCity / NBU / NSSMCTimeline: PlayCity gambling licences: 15 working days statutory review. NBU bank decisions: 2 months from a complete filing. Crypto VASP regime: pending second reading of Bill 10225-d.
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United Kingdom

The FCA currently registers cryptoasset firms under the MLRs 2017. The FSMA (Cryptoassets) Regulations 2026 introduce full authorisation, with applications opening 30 September 2026.

Regulator: Financial Conduct Authority (FCA)Timeline: FCA cryptoasset registration has a statutory three-month determination period. FSMA authorisation window runs 30 September 2026 to 28 February 2027.
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Middle East

10 jurisdictions

Bahrain

The Central Bank of Bahrain licenses crypto-asset services under Volume 6 of the CBB Rulebook, covering four CRA categories, the 2025 Stablecoin Issuance Module and AML rules.

Regulator: Central Bank of Bahrain (CBB)Timeline: CBB licensing is substantive, with no statutory deemed-decision period. Marketing without a CBB licence within or from Bahrain is prohibited.
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Crypto License in Dubai

Dubai's Virtual Assets Regulatory Authority (VARA) licenses all virtual asset activity carried on by way of business, unless an exemption applies.

Regulator: Dubaiโ€™s Virtual Assets Regulatory Authority (VARA).
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Dubai (UAE)

Dubai's Virtual Assets Regulatory Authority (VARA) is the sole regulator for virtual asset activity across Dubai under Law No. 4 of 2022, excluding the DIFC. All VASPs must be VARA-licensed.

Regulator: VARA / DFSA / SCA
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Israel

Israel's Capital Market, Insurance and Savings Authority licenses virtual-currency businesses as financial asset service providers. Virtual currency is treated as a financial asset.

Regulator: Capital Market, Insurance and Savings Authority (CMA)Timeline: Financial asset service licensing is substantive, with enhanced AML and customer-monitoring review. The first payment service licences issued in July 2025.
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Kuwait

Kuwait enforces an "absolute prohibition" on virtual assets โ€” crypto payments, investment, services/licensing and mining are banned by coordinated 17 July 2023 circulars from the Central Bank of Kuwait, the Capital Markets Authority, the Insurance Regulatory Unit and the Ministry of Commerce. Electronic payments and e-money are regulated by the Central Bank of Kuwait under Resolution No. 45/471/2023 (replacing the 2018 instructions), within Law No. 20 of 2014 on electronic transactions. Gambling is comprehensively prohibited under the Kuwaiti Penal Code (Law No. 31 of 1970) and Islamic Sharia law; there is no regulator or licence.

Regulator: Central Bank of Kuwait (CBK)Timeline: No crypto licensing timeline โ€” crypto is absolutely prohibited and no licences are issued. Payments/e-money: CBK registration/licensing under Resolution No. 45/471/2023 (no single published statutory clock; CBK may suspend registration if the activity is not performed within six months). Gambling: not applicable โ€” prohibited.
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Oman

Oman has no enacted standalone crypto law yet, but the Capital Market Authority (now Financial Services Authority) is actively building a Virtual Assets Regulatory Framework โ€” announced February 2023, with public consultations in 2023 and a finalising consultation in 2025 โ€” to license all VASP categories; crypto is currently captured by AML/CFT rules (Royal Decree No. 30 of 2016) and CMA Decision No. E/35/2023. Payments and e-money are regulated by the Central Bank of Oman under the National Payment Systems Law (Royal Decree No. 8/2018) and its 2019 Executive Regulation. Gambling is comprehensively prohibited under the Basic Law (Sharia basis) and the Omani Penal Law; there is no regulator or licence.

Regulator: Financial Services Authority (FSA, formerly CMA)Timeline: Crypto: no licensing timeline yet โ€” the VARF is in development (announced 2023; finalising consultation 2025); only AML/CFT registration (CMA Decision No. E/35/2023) currently applies. Payments/e-money: CBO licensing under the National Payment Systems Law (no single published statutory clock); FinTech sandbox minimum 6 months. Gambling: not applicable โ€” prohibited.
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Qatar

The QFC Digital Assets Framework (2024) licenses tokenisation and investment tokens via the QFCRA. QCB covers mainland banking and payments; QFMA covers tokenised securities.

Regulator: QFC Authority / QFCRA, QCB, QFMATimeline: QFC token service licence is required before any token validation, generation, custody, exchange or transfer activity. QFC AML/CFT Rules Version 6 take effect 1 May 2026.
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Saudi Arabia

Restrictive jurisdiction. No retail VASP licence; SAMA licenses Payment Service Providers under the Law of Payments and Payment Services. Gambling is fully prohibited under Sharia.

Regulator: Saudi Central Bank (SAMA)Timeline: SAMA PSP licence: substantive review under the Implementing Regulations of the LPPS. SAMA Sandbox: typically 6โ€“12 months pilot before any consideration of full authorisation.
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Turkey

Turkey's Capital Markets Board licenses crypto-asset service providers under Law No. 7518 and 2025 communiquรฉs. MASAK handles AML; TCMB enforces the payment-use ban.

Regulator: Capital Markets Board of Turkey (CMB / SPK)Timeline: CMB authorisation is required to operate. In March 2026 CMB extended deadlines for Operating List providers to obtain authority certificates.
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United Arab Emirates

The UAE splits virtual-asset oversight between SCA federally, CBUAE for payment tokens, Dubai's VARA, ADGM FSRA and DIFC DFSA. Groups often need multi-regulator analysis.

Regulator: SCA, CBUAE, Dubai VARA, ADGM FSRA, DIFC DFSATimeline: VARA requires authorisation before any virtual-asset activity, with a separate licence per activity. ADGM FSRA fiat-referenced token rules took effect 1 January 2026.
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Africa

19 jurisdictions

Algeria

Algeria is not a crypto or private iGaming licensing jurisdiction. The viable regulatory routes are in financial services, under the Bank of Algeria.

Regulator: Bank of AlgeriaTimeline: PSP: 12 months to approval, then 12 months to launch. Banks: two-stage approval by the Bank of Algeria.
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Chad

CEMAC member with no national crypto law; crypto effectively prohibited for regulated financial institutions under regional COBAC Decision D-2022/071 of 6 May 2022, and BEAC reaffirmed opposition in January 2024. Payments and e-money regulated regionally under CEMAC Regulation No. 04/18/CEMAC/UMAC/CM/COBAC of 21 December 2018 (in force 1 January 2019), authorised by the national monetary authority on COBAC approval. Gambling (casinos, sports betting, lotteries, raffles) is legal and licensed under general law via the ministries of commerce and finance, with no dedicated regulator and online in a legal grey area.

Regulator: Bank of Central African States (BEAC)Timeline: No crypto licensing timeline โ€” crypto is prohibited for regulated financial institutions; no national framework. Payment-services authorisation runs through the national monetary authority subject to COBAC approval (no single published statutory clock). Gambling licensing is handled case-by-case by the relevant ministry; no transparent statutory timeline.
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Democratic Republic of the Congo

No enacted crypto or virtual-asset law โ€” a draft Digital Assets Bill remained in inter-ministerial/parliamentary review through 2025โ€“2026. Payments and e-money are licensed by the Banque Centrale du Congo under Instruction No. 24 of 11 November 2011 (EMI minimum capital US$2.5m), with Instruction No. 58/2024 mandating mobile-money/payment-network interoperability. Gambling is split between the Ministry of Finance, the Ministry of Sports and Leisure and the state lottery SONAL (established by 1984 ordinance), with no enacted online regime.

Regulator: Banque Centrale du Congo (BCC)Timeline: No statutory crypto licensing timeline (no crypto law). BCC payments/e-money authorisation runs on the central bank's assessment of business model, management and technical infrastructure (no published fixed clock). Gambling licensing has no single transparent timeline given the multi-desk structure.
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Egypt

Crypto prohibited under Article 206 of Law No. 194 of 2020. Payments licensed by the CBE under the comprehensive 2025 PSP/PSO Rules. Gambling is criminalised for Egyptian citizens but legal at licensed land-based casinos for non-Egyptian passport holders only.

Regulator: Central Bank of Egypt (CBE)Timeline: CBE PSP/PSO licence: prior approval decision within 90 days from complete application. 12-month PSP transition window to June 2026. Casino licence: 6โ€“12 months.
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Ghana

Crypto legalised 30 December 2025 with the Virtual Asset Service Providers Act (Act 1154). Dual-regulator: BoG (payments/stablecoins) + SEC (exchanges/custody/tokens). Gambling under Gaming Act 2006 with five licence classes via the Gaming Commission.

Regulator: Bank of Ghana (BoG)Timeline: VASP licensing: detailed directives expected Q1 2026; full operationalisation typically 2 years per BoG. SEC sandbox: 12 months with 6-month midpoint review. Gaming Commission licence: typically 6โ€“12 months.
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Kenya

Kenya has three separate licensing tracks: crypto (VASP Act 2025), regulated financial services (CBK/CMA), and gambling (Gambling Control Act 2025). Each has its own regulator and timeline.

Regulator: Capital Markets Authority (CMA)Timeline: PSP authorisation in 7 days; money remittance letter of intent in 90 days; digital credit decision in 60 days; online gambling licence runs 36 months.
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Libya

Libya bans cryptocurrency โ€” the Central Bank of Libya declared virtual currencies illegal in 2018 and enforcement continues (2025 mining prosecutions); no national crypto law. Payments and e-money are controlled solely by the Central Bank of Libya under Banking Law No. 1 of 2005 (amended Law No. 46 of 2012; interest prohibited Law No. 1 of 2013) via the National Payments Council. Gambling is criminally prohibited under Penal Code Articles 492โ€“495 and, for online, Article 31 of Cybercrime Law No. 5 of 2022. Politically divided jurisdiction with significant sanctions and country-risk exposure.

Regulator: Central Bank of Libya (CBL)Timeline: No crypto licensing timeline โ€” crypto is illegal; no framework. Payments/e-money licensing runs through the CBL/National Payments Council (no single published statutory clock; general company formation reported at two to three months). Gambling: not applicable โ€” prohibited.
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Mali

Mali is a WAEMU member with no domestic crypto law; crypto sits in a legal grey zone and the only tangentially applicable instrument is BCEAO Instruction No. 008-05-2015 on electronic-money issuers (AML/CFT). Payments and e-money are regulated regionally by the BCEAO under Instruction No. 008-05-2015 and Instruction No. 001-01-2024 (in force 23 January 2024; PI and EMI categories; transition extended to 31 August 2025), licensed country-by-country. Gambling is state-controlled: PMU-Mali (created 1994; absorbed the national lottery LONAMA in 2003) is the sole authorised betting/lottery operator, and casinos are legal in 5-star hotels under Law No. 96-021 of December 1995; online unregulated. Acute post-2021 political-transition and announced ECOWAS-exit context.

Regulator: Central Bank of West African States (BCEAO)Timeline: No crypto licensing timeline โ€” there is no crypto framework. Payments/e-money: applications to the BCEAO Governor; the transition window for existing operators ran (after extension) to 31 August 2025; no fixed statutory clock for new applicants and approvals reported as slow. Gambling: betting/lottery is a closed PMU-Mali franchise (no private licensing route); casino authorisation under the 1995 law is administrative and discretionary.
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Mauritania

Mauritania has no specific crypto law; cryptocurrencies are not legal tender, the Banque Centrale de Mauritanie (BCM) has warned about crypto risk, and Islamic-finance principles shape the regulatory approach (the BCM is exploring a "digital ouguiya" CBDC with Giesecke+Devrient from April 2024). Electronic payments are regulated by the BCM under the June 2021 electronic-payment-services law, with the GIMTEL national switch and growing mobile money. Gambling is comprehensively prohibited as Mauritania is an Islamic Republic whose legal system is based on Sharia; there is no regulator, statute or licence.

Regulator: Banque Centrale de Mauritanie (BCM)Timeline: No crypto licensing timeline โ€” there is no crypto framework (warning only). Payments/e-money: BCM authorisation under the June 2021 electronic-payment-services law (no single published statutory clock). Gambling: not applicable โ€” prohibited.
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Mauritius

One of few African jurisdictions with live licensing across crypto (FSC under VAITOS), banking and payments (Bank of Mauritius), and remote betting and digital gaming (GRA).

Regulator: Financial Services Commission (FSC)Timeline: Bank and PSP: 30 days completeness review, then 60 working days. VASP decision SLA not published.
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Morocco

Morocco is in transition: from the November 2017 prohibition of crypto transactions to Draft Bill 42.25 (November 2025) proposing AMMC-licensed CASPs and BAM-regulated stablecoins, MiCA-aligned but not yet enacted. Gambling is legal under Dahir No. 1-65-206 of 1966 via state monopolies.

Regulator: Bank Al-Maghrib (BAM)Timeline: Bill 42.25: pending enactment as of May 2026. Crypto licensing rules subject to enactment and secondary regulations. Land-based casino licence via Ministry of Finance and tourist-area authorisation. State monopoly partnerships: public-tender procedures.
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Niger

WAEMU member with no domestic crypto law; crypto sits in a legal grey zone and the only tangentially applicable instrument is BCEAO Instruction No. 008-05-2015 on electronic-money issuers (AML/CFT). Payments and e-money regulated regionally by the BCEAO under Instruction No. 008-05-2015 and the new Instruction No. 001-01-2024 (effective 23 January 2024; PI and EMI categories; transition ended 1 May 2025), licensed country-by-country. Gambling is a state monopoly run by the National Lottery of Niger (LONANI); no private-operator licensing and online unregulated. Acute post-2023 political-transition and announced ECOWAS-exit context.

Regulator: Central Bank of West African States (BCEAO)Timeline: No crypto licensing timeline โ€” there is no crypto framework. Payments/e-money: applications to the BCEAO Governor; a transition window for existing operators ran to 1 May 2025; no fixed statutory clock for new applicants and approvals have been reported as slow. Gambling: not applicable for private operators โ€” state monopoly, no licensing route.
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Nigeria

Nigeria is not a one-regulator jurisdiction. Crypto falls under SEC, payments under CBN, and iGaming is state-level. The correct path depends on your exact product.

Regulator: Securities and Exchange Commission (SEC)Timeline: SEC ARIP gives approval-in-principle in weeks. CBN payment licences run on a 6-month AIP. Lagos betting licences renew annually.
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Republic of the Congo

No national crypto law; IMF lists Republic of Congo among CEMAC states with effective crypto bans; COBAC Decision of May 2022 prohibits banks, microfinance and payment institutions from facilitating crypto transactions. Payments and e-money regulated regionally under CEMAC Regulation No. 04/18/CEMAC/UMAC/CM/COBAC of 21 December 2018 (in force 1 January 2019), authorised by the national monetary authority on COBAC approval. Gambling consolidated under national Law No. 37-2024 of 12 December 2024, alongside the state lottery operator COGELO under the Ministry of Finance.

Regulator: Bank of Central African States (BEAC)Timeline: No crypto licensing timeline โ€” crypto is prohibited for regulated financial institutions; no national framework. Payment-services authorisation runs through the national monetary authority subject to COBAC approval (no single published statutory clock). Gambling licensing follows Law No. 37-2024 categories; historically operators required a presidential decree countersigned by the finance ministry (5โ€“10 year validity).
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Rwanda

First virtual asset law unanimously adopted by Parliament on 5 May 2026. CMA designated primary regulator; NBR coordinates financial stability. Gambling regulated by Rwanda Development Board under the 2024 Gambling Policy and legacy Law nยฐ58/2011; licensing resumed 1 August 2025.

Regulator: Capital Market Authority of Rwanda (CMA)Timeline: Virtual asset licensing: law adopted 5 May 2026; in force on Official Gazette publication; implementing regulations to follow. Gambling: RDB resumed licensing 1 August 2025 after a 13-month freeze; Expression of Interest process for new entrants.
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Seychelles

Seychelles is FSA-regulated for crypto (VASP Act 2024), securities, fund management and gambling, with the Central Bank licensing banks under the Financial Institutions Act 2004.

Regulator: FSA / Central Bank of SeychellesTimeline: FSA reviews VASP, Securities Dealer and gambling licences case by case. Central Bank reviews offshore banking case by case. No fixed statutory clocks.
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South Africa

Crypto licensing available via FSCA; banking available via the Prudential Authority; online sports betting available province by province. Private online casino licensing is not available nationally.

Regulator: Financial Sector Conduct Authority (FSCA)Timeline: FSCA CASP decision period not published; commercial bank about 6 to 9 months with a 12-month window to registration; provincial bookmaker licences run on each board's own timing.
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Sudan

No virtual-asset law; the Central Bank of Sudan warned in March 2022 that cryptocurrencies are not money or property and carry high risk โ€” only the Electronic Transactions Act 2007 (pre-Bitcoin) plus AML circulars apply. Payments and e-money are controlled by the CBOS via the state-owned Electronic Banking Services (EBS) switch under the Banking Business Act and revised post-2020 e-money regulations. Gambling is criminally prohibited under the Sudan Criminal Act 1991 and Sharia. The country is in active armed conflict since April 2023 with fractured financial infrastructure and severe sanctions exposure.

Regulator: Central Bank of Sudan (CBOS)Timeline: No crypto licensing timeline โ€” there is no framework (warning only). Payments/e-money licensing runs through the CBOS and EBS integration (no single published statutory clock; heavily disrupted by the conflict). Gambling: not applicable โ€” prohibited.
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Tunisia

Tunisia prohibits unauthorised crypto under a May 2018 Central Bank of Tunisia (BCT) directive enforced through the foreign-exchange-control code (penalties up to five years' imprisonment); a draft March 2024 exchange code would permit BCT-authorised crypto holding/exchange but is unenacted. Payments and e-money are regulated by the BCT under Banking Law No. 2016-48 of 11 July 2016. Gambling is tightly state-controlled: casinos under Decree-Law No. 74-21 of 1974 (non-residents only), and a Promosport state monopoly over sports betting and lotteries (including online) under Law No. 84-63 of 1984; a January 2026 bill would criminalise unlicensed online gambling.

Regulator: Banque Centrale de Tunisie (BCT)Timeline: No crypto licensing timeline โ€” crypto is prohibited and there is no licence (sandbox entry only, time-bound). Payments/e-money: BCT authorisation under Banking Law No. 2016-48 (no single published statutory clock). Casino: rare, discretionary joint-ministerial authorisation (process not publicly detailed). Sports betting/lottery: closed (Promosport monopoly).
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Asia Pacific

14 jurisdictions

Australia

Australia has no single crypto licence. AUSTRAC handles VASP registration and ASIC oversees AFSL and market licensing. The Digital Assets Framework Act 2026 adds a platform AFSL from 9 April 2027.

Regulator: AUSTRAC and ASICTimeline: AUSTRAC VASP registration: deemed refusal at 90 days, extendable by 30. AFSL applications typically take several months.
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Hong Kong

Hong Kong runs activity-specific regimes. The SFC licenses virtual asset trading platforms under the SFO and AMLO, while the HKMA licenses fiat-referenced stablecoin issuers from 1 August 2025.

Regulator: Securities and Futures Commission (SFC) and Hong Kong Monetary Authority (HKMA)Timeline: VATP licensing runs on substantive SFC review with no statutory deemed-decision period. HKMA stablecoin issuer review is case by case.
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India

India has no single VDA licence. Providers register with FIU-IND under the PMLA, and the Income-tax Act 2025 adds a 30% tax, 1% withholding and crypto transaction reporting from April 2026.

Regulator: Financial Intelligence Unit: India (FIU-IND), Ministry of Finance, CBDT, RBI and SEBITimeline: FIU-IND registration requires in-person review with the Designated Director and Principal Officer; no statutory decision deadline.
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Indonesia

Indonesia regulates cryptoassets through the OJK, which took over from Bappebti on 10 January 2025. OJK licenses exchanges, clearers, custodians and traders under PP 49/2024 and POJK rules.

Regulator: Otoritas Jasa Keuangan (OJK)Timeline: OJK licensing is substantive and entity-based with no statutory deemed-decision period since the Bappebti transition in January 2025.
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Japan

Japan uses activity-specific regimes overseen by the FSA. Crypto exchanges register under the Payment Services Act; tokenised securities sit under the FIEA. A 2026 PSA-to-FIEA bill is pending.

Regulator: Financial Services Agency (FSA)Timeline: FSA cryptoasset exchange registration runs on substantive review with no statutory deemed-decision period. EPI registration follows the same path.
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Kazakhstan

Dual track: AFSA inside the AIFC for crypto, custody, broking and payments under common-law rules; Ministry of Digital Development for mining and non-AIFC circulation. Gambling under Ministry of Tourism and Sports.

Regulator: Astana Financial Services Authority (AFSA)Timeline: AFSA digital asset licence: about 6โ€“7 months from incorporation to operating launch. Outside-AIFC crypto and gambling routes run separately.
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Malaysia

The Securities Commission Malaysia regulates digital assets under the CMSA 2007 and the 2019 Prescription Order, treating qualifying digital tokens and currencies as securities.

Regulator: Securities Commission Malaysia (SC)Timeline: SC licensing is substantive and entity-based with no statutory deemed-decision period for DAX or DAC applications.
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Pakistan

Pakistan launched its first crypto-licensing regime in July 2025 under the Virtual Assets Ordinance, formalised as the Virtual Assets Act in February 2026. PVARA licenses VASPs. Gambling is prohibited under the 1977 Prevention of Gambling Act.

Regulator: Pakistan Virtual Assets Regulatory Authority (PVARA)Timeline: PVARA NOC stage: rolling-basis review via email. Full licensing framework: secondary regulations being finalised; first NOCs granted December 2025 (Binance, HTX).
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Philippines

The Philippines runs parallel crypto regimes: BSP VASP licences are under moratorium; SEC's 2025 CASP Rules cover platforms serving Filipinos. PAGCOR handles domestic gambling.

Regulator: Bangko Sentral ng Pilipinas (BSP) / Securities and Exchange Commission (SEC) / PAGCORTimeline: BSP VASP: new applications under moratorium (only existing BSP-supervised institutions with stable SAFr rating may apply). SEC CASP review via PhiliFintech Innovation Office.
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Singapore

MAS regulates crypto by activity, not one licence. Payment Services Act 2019 covers digital token services; from 30 June 2025, FSMA Part 9 covers Singapore providers serving overseas.

Regulator: Monetary Authority of Singapore (MAS)Timeline: MAS payment institution licensing is substantive with no statutory deemed-decision period. MAS states it will generally not issue an FSMA DTSP licence.
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South Korea

South Korea regulates virtual assets through VASP reporting to KoFIU under the SFTIA, plus the Virtual Asset User Protection Act 2024 enforced by the FSC and FSS, not a single crypto licence.

Regulator: Financial Services Commission (FSC), Korea Financial Intelligence Unit (KoFIU) and Financial Supervisory Service (FSS)Timeline: KoFIU VASP reporting is time-limited up to five years, then renewable. FIU may refuse, cancel, or suspend reporting for up to six months.
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Sri Lanka

No crypto law in force as of May 2026; Concept Paper for regulating virtual assets presented 12 February 2026, new laws expected in 2026, FIU running a mandatory VASP survey. Gambling consolidated under the Gambling Regulatory Authority Act, No. 17 of 2025, in force from 1 December 2025, establishing the unified GRA.

Regulator: Gambling Regulatory Authority (GRA)Timeline: Crypto: Concept Paper presented 12 Feb 2026; new laws expected 2026; FIU VASP registration ahead of Sri Lanka's FATF AML/CFT evaluation. GRA: Act in force 1 December 2025; formal institutional establishment targeted by 30 June 2026.
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Thailand

The Thai SEC licenses digital asset businesses under the 2018 Emergency Decree, as amended in 2025 to capture offshore operators serving Thai users. Six business categories are supervised.

Regulator: Securities and Exchange Commission (SEC) and Minister of FinanceTimeline: SEC licensing is mandatory before any regulated digital asset activity, with substantive review and no deemed-decision period.
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Vietnam

Vietnam licenses crypto through a five-year MoF pilot, payments through the SBV, and gambling sector-by-sector (casinos, e-games, sports betting). Online casinos are prohibited.

Regulator: MoF / SBV / SSCTimeline: CASP licence: 20 working days initial review, up to 12 months for supplementary dossier, 30 days appraisal. SBV IPS licence: up to 60 working days. Casino and e-game licences: case-by-case.
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