1. [Statutory business classification and regulatory characteristics] of Bahrain CASP license
Four-level classification license system
Category 1 onlyBrokerage Consultant；Category 2 allows custody and agency transactions；Category 3 covers proprietary market making；Category 4 is the highest authority，Legally allowed to operatecrypto asset exchange(B.S.C only. architecture)。
0% Corporate tax and capital gains tax
BahrainApplicable to crypto asset companies 0% corporate income tax，and exempt from capital gains tax and withholding tax。Only handling fees generated for crypto asset services are applicable in accordance with the law. 10% Standard VAT (VAT)。
2025Year Stablecoin Issuance Framework
CBB implements the "Issuance and Provision of Stablecoins" (SIO) Module》。Licensed companies are legally allowed to issue BHD、Single-currency fiat-backed stablecoins pegged to USD and others，Mandatory requirements 1:1 Reserve asset pledge。
Strict token listing approval system
The exchange strictly prohibits random listing of coins。Only “Accepted Crypto-Assets” with CBB’s prior written approval (Accepted Crypto-Assets)"Provide services，Darknet trading tokens were vetoed by one vote in accordance with the law。
2. Industry information：Middle East encryption field [case of legally approved licensed representative]
Global leading exchange：Binance (Binance)
Set up a branch in Bahrain，2022Became the first company to be approved 4 kind (Category 4) Fully licensed crypto exchange。Approved to operate a complete trading platform and entrusted custody services。
Institutional Grade OTC Trading：ARP Digital
Approved 3 Class license。Bahrain’s only OTC exchange specializing in digital asset structured products (OTC) mechanism，Provide customized solutions for family offices and high-net-worth individuals。
Middle East Compliance Pioneer：Rain
The first encryption company in the Middle East to obtain a CBB license。2017The first batch to enter the regulatory sandbox and graduate in 2019，Get the first 3 CASP-like license，Provide legal currency deposits and asset storage。
Regional asset management：Fasset / CoinMENA
Fasset focuses on RWA and digitalasset Management，CoinMENA focuses on multi-currency in the Middle EastFiat currency deposits and withdrawals。Both institutions have obtained the first 3 License to carry out brokerage and trading business。
3. Bahrain CBB’s [Statutory paid-in capital and fee standards] for CASP licenses
| Statutory license type | Legal minimum paid-in capital (BHD) | Official application fee / Annual license fee basis (BHD) |
|---|---|---|
| No. 1 kind (Category 1) *consult / Broker (Forbidden client assets) |
lowest 25,000 BHD (about 6.6 million U.S. dollars) |
Apply：100 / Annual fee minimum：2,000 |
| No. 2 kind (Category 2) *agency transaction / hosting (Self-employment prohibited) |
lowest 100,000 BHD (about 26.5 million U.S. dollars) |
Apply：100 / Annual fee minimum：3,000 |
| No. 3 kind (Category 3) *proprietary trading / market making (client) |
lowest 200,000 BHD (about 53.0 million U.S. dollars) |
Apply：100 / Annual fee minimum：4,000 |
| No. 4 kind (Category 4) *Cryptoasset exchange operators |
lowest 300,000 BHD (about 79.5 million U.S. dollars) |
Apply：100 / Annual fee minimum：5,000 |
Legal Notes：The above capital must be paid in full to a local retail bank in Bahrain before the license is issued.。In addition to registered capital，Licensed institutions must also hold additional highly liquid assets sufficient to cover expected operating expenses for no less than three months。The annual license fee is based on the licensee’s operating expenses for the previous fiscal year. 0.25% Calculate and collect，The maximum limit is 12,000 BHD。
4. [Corporate governance and local substantive (Substance) Require】
Local content and physical office：W.L.L must be legally registered in Bahrain. or B.S.C.. Corporations (Category 4 B.S.C only. or overseas branch)。Must have an actual physical office space，The use of virtual offices or mailboxes is absolutely prohibited。
Executive resident and controlled functions (Controlled Functions)：CEO (CEO)、Compliance officer、money laundering reporting officer (MLRO)、chief information security officer (CISO) Legal executives must be resident in Bahrain，Non-Bahrain residents are subject to special exemption from CBB。
suitability review (Fit & Proper)：All controlled function executives and directors must pass rigorous CBB background checks，Provide proof of no criminal record，And have relevant financial/technical professional experience。
Compulsory insurance and prevention of conflicts of interest：Institutions handling client funds must compulsorily purchase and maintain professional liability insurance (PII)。No. 4 Class exchanges are expressly prohibited from using their own capital to hedge customer orders (to prevent principal matching transactions)。
5. [List of statutory registration and audit documents submitted to Bahrain CBB for review]
| File category | Submission details of statutory requirements and interpretation of regulatory core |
|---|---|
| Statutory application forms and executive due diligence | Form 1 (License application form)、Form 2 (Authorization from major shareholders)、Form 3 (Controlled function executive approval)。Criminal certificates and resumes of all shareholders and executives。 |
| Business planning and financial forecasting | detailedbusiness plan (Business Plan)，Must cover the future at least 3 financial forecast statement for the year、Funding sources and marketing strategies。 |
| Compliance and internal controland cybersecurity programs | AML/CFT policy manual、Cybersecurity Risk Assessment Report。Protection measures for hot and cold wallet private key storage、Client asset segregation procedures and copy of professional liability insurance policy。 |
6. [Statutory Application and CBB Approval Process] for Bahrain CASP License
first stage：Pre-application meeting and preparation (about 1-2 months)
Hold a Pre-Application Meeting with CBB to confirm license type。At the Ministry of Industry and Commerce (MOIC) reserved name，Prepare business plan and form 1-3 Application dossier。
second stage：Force sandbox testing (2025new regulations)
All new applicants for crypto licenses must be forced to enter the "regulatory sandbox" (Regulatory Sandbox)” conduct pilot testing。Approx. required 1,250 BHD Sandbox Processing Fee。
The third stage：Submission of application and substantive examination (legal 60 day)
Pay to CBB 100 BHD application fee and submit a complete set of case files。After all documents are in place，The CBB Act is stipulated in 60 Respond within calendar days and issue "approval in principle" (IPA)”。
Stage 4：On-site preparation and capital injection verification (longest 6 months)
After being issued an IPA 6 within months，Complete Bahrain MOIC final registration。Open a local bank account and deposit minimum paid-in capital，Implement office leasing and resident executive allocation。
The fifth stage：System evaluation and formal licensing (total cycle 3-6 months)
System readiness assessment completed by an independent third party (Readiness Assessment)。After meeting the conditions, CBB will issue a formal license，The organization must be in 6 Start business in accordance with the law within months。
7. Hong Kong Huitong's Bahrain CASP license legal agency service
Local corporate establishment and physical implementation
Apply for B.S.C in Bahrain. or W.L.L.. Setup。Assistance with leasing physical office space，Match and introduce resident executives who meet CBB suitability review in accordance with the law (MLRO/CISO)。
Compilation of compliance documents and risk control system
Compose contains 3-5 Annual financial forecast business plan。Develop an AML/CFT policy manual that strictly adheres to FATF standards、Cybersecurity framework and customer asset isolation procedures。
CBB defense and local capital verification and account opening
Fully authorized agent to submit Form to CBB 1-3 Case file and sandbox application，Respond to written inquiries。Assist in opening compliant accounts with local retail banks in Bahrain，And recommend independent auditors to issue capital verification and system assessment reports。
8. Bahrain CASP Cryptocurrency License Core Legal Questions and Answers (FAQ)
allow。Foreign investment is allowed 100% Wholly-owned holding。The applicant must register as a Bahrain limited liability company (W.L.L.) or joint stock company (B.S.C.)。But the first 4 Class exchange license only B.S.C.. Structure or overseas branch。
Absolutely prohibited。CBB strictly implements “substantive management (Mind and Management)"Require。Must establish a designated physical office in Bahrain，Have local IT infrastructure，Virtual offices prohibited。
In principle, it must be permanent。CEO、Compliance officer、money laundering reporting officer (MLRO) and chief information security officer (CISO) are subject to CBB’s “suitability (Fit & Proper)"review，Non-Bahrain residents are subject to special exemption from CBB。
Divided into four categories。Category 1 is for consulting brokers only (client assets are prohibited)；Category 2 allows custody and agency transactions (self-operation prohibited)；Category 3 allows self-operated market making；Category 4 is the highest authority，Allowed to operate crypto asset exchanges。
Legal funds must be paid in full and deposited in a local bank in Bahrain。Category 1 25,000 BHD；Category 2 100,000 BHD；Category 3 200,000 BHD；Category 4 Exchange 300,000 BHD。In addition, coverage is required 3 Current assets for monthly operating expenses。
Applicable 0% corporate income tax，and exempt from capital gains tax、Personal income tax and withholding tax。Only handling fees generated for crypto asset services are applicable in accordance with the law. 10% Standard VAT (VAT)。
After the applicant submits all statutory documents and is deemed "complete"，The CBB’s statutory review period is 60 calendar days。After being issued the IPA, there are 6 Complete business establishment and capital injection within months，The overall licensing cycle is approximately 3-6 months。
2025After the implementation of the new regulations，All new applicants for crypto licenses (regardless of whether they have overseas licensing experience) must enter the regulatory sandbox for pilot testing。Need to pay 1,250 BHD Sandbox Processing Fee。
It is strictly prohibited to put it on the shelves at will。Services may only be provided in respect of "Accepted Crypto-Assets" with CBB's prior written approval。Issuance of stablecoins must be registered with B.S.C.. structure and satisfy 1:1 Legal currency pledge，DTOs with security characteristics must be approved for white paper。
support。After obtaining the IPA, you can open a basic corporate account in a local bank in Bahrain for capital verification.。However, banks will perform independent and rigorous KYC/AML due diligence on crypto companies.，The actual account opening period needs to be reserved 2-3 months。
Quarterly and annual financial audits must be performed by independent external auditors approved by the CBB。Every 6 An external agency must perform a customer asset isolation compliance audit and network security penetration test every month。
The license is renewed annually。The licensee must annually 12 moon 1 Pay the license fee for the next year before。Based on total operating expenses for the previous fiscal year 0.25% Calculate and collect，The legal minimum limit for Category 4 licenses is 5,000 BHD，The upper limit is 12,000 BHD。
