1. [Legal business authority and regulatory characteristics] of Gibraltar DLT license
Nine core regulatory principles
GFSC legally adopts 'principles-based' framework to replace rigid rules. Assessment covers honesty and integrity, System security, Customer asset protection, Nine statutory dimensions including corporate governance and prevention of financial crimes.
Core DLT business authorization
Authorize enterprises to use according to lawDistributed Ledger Technology (DLT) Store or transfer value to others, Legal authority fully covers cryptocurrency secondary market transaction matching and wallet asset custody services.
FATF Whitelist and Compliance Credibility
Gibraltar has officially FATF Removed from gray list, Anti-money laundering regulatory standards are in line with those in the UK. The regulatory framework helps banks understand the compliance basis of licensed institutions, However, whether to open an account is still decided by the bank based on independent due diligence and risk policies..
Classification Fees and Capital Discretion
GFSC legally divides applicants into three categories based on business complexity (Category 1-3), Tiered collectionstatutory fees. No statutory unified capital bottom line, Determine sufficient liquidity required based on specific business risks.
2. Blog: Gibraltar DLT [Case of Legally Approved Licensed Representative]
Banking and Custody: Xapo Bank
One of the first institutions in the world to obtain dual banking and DLT licenses. Legally store/transmit Bitcoins according to law, and provides coverage under the Gibraltar Deposit Protection Scheme (up to 12 Thousands of pounds) protected fiat/crypto hybrid account.
Institutional Grade Trading: LMAX Digital
A cross-border crypto exchange established by a foreign exchange institution regulated by the FCA (approved in 2019). The license allows it to operate secondary markets and custody for institutional investors such as hedge funds., Introducing traditional financial risk control standards.
Innovative comprehensive transaction: Bullish
Exchange incubated by Block.one. The focus of the application is to verify the compliance of the "hybrid order book" and "asset pool" mechanisms, Its statutory license covers leveraged trading, Complex products such as custody and perpetual contracts.
Regional leaders and retail investors: Name / eToroX
Latin American giant Bitso relies on this license to establish international compliance standards for the Travel Rule; Exclusively for eToro eToroX department, Approved to operate exchanges and wallets, Provide compliant digital asset services to global retail investors in accordance with the law.
3. GFSC’s [Statutory Business Classification and Fee Standards] for DLT Licenses
| Legal Business Complexity Classification | Statutory initial appraisal fee | Statutory filing fee (Application Fee) | annual supervision fee (Annual Fee) |
|---|---|---|---|
| Category 1 (low complexity) | £ 2,000 | £ 10,000 | £ 10,000 |
| Category 2 (medium complexity) | £ 2,000 | £ 20,000 | £ 20,000 |
| Category 3 (high complexity) | £ 2,000 | £ 30,000 | £ 30,000 |
Legal Notes: Most conventional multi-asset cryptocurrency exchanges are legally classified by the GFSC as Category 2 or Category 3. The statutory capital is independently approved by GFSC based on the business business plan and risk modeling., Must demonstrate sufficient liquidity to maintain business resilience and orderly winding down.
4. [Corporate governance and local substantive statutory requirements] for Gibraltar DLT
Local Entity vs. Physical Office Content: A private limited company must be legally registered in Gibraltar. Core functions of management and control must be located onshore, and must lease and operate a real physical office space, Absolutely reject pure empty shell architecture.
Local configuration of employees and executives: Practical review usually requires at least 2 A local employee in Gibraltar. A money laundering reporting officer responsible for establishing internal rules must be appointed by law (MLRO) and resident compliance director.
Fit and proper review (Fit & Proper): All controllers, Directors and officers must submit detailed resumes, and pass the GFSC’s stringent compliance and suitability tests covering financial integrity, Professional ability and no criminal conviction record).
Insurance mechanism and system security audit: When it comes to the fiduciary management of client assets, Legally required to have professional liability insurance that meets regulatory requirements (PII). and must implement a high-level cybersecurity plan and independent system testing.
5. [List of dossiers for statutory review] submitted to GFSC
| File category | Submission details of statutory requirements and interpretation of regulatory core |
|---|---|
| Basic corporate and individual due diligence materials | Gibraltar Private Limited Company Certificate of Incorporation and Articles of Association. All controllers, "Personal/Company Questionnaire" for Directors and Senior Management, Include detailed background certificate and legal fund/wealth source certificate. |
| Business Planning and Product White Paper | business plan (Whitepaper). Product and service details must be described in detail, target customer group, Underlying operating platform technology mechanism, and future 3 Detailed financial forecasts and capital liquidity calculations for the year. |
| Compliance, Internal Control and Cybersecurity Procedures | AML/KYC Enforcement Manual and Policy Procedures. risk management framework, professional liability insurance (PII) certificate, Cyber Security Plan (Private Key Storage Protection) and Solvent Business Closure (Wind-down) plan. |
6. Gibraltar DLT License [Statutory Application and GFSC Approval Process]
first stage: Corporate establishment and preliminary preparations (about 1 months)
Register a legal entity in Gibraltar. Establish local substantial office space, Recruitment and appointment of local employees and MLROs. Write business plans and various internal compliance manuals.
second stage: Submit Initial Proposal and Evaluate Classification
Submit summary of initial business proposal to GFSC, and pay an initial assessment fee of £2,000. GFSC determines the business category based on the complexity of the proposal (Category 1-3).
The third stage: Formal application and substantive examination (about 3-6 months)
Pay the statutory application fee for the corresponding category (£10,000 – £30,000), Submit a complete case file including white paper and executive due diligence. GFSC conducts substantive reviews and inquiries based on nine core principles.
Stage 4: Licensing approval and compliance implementation
Satisfy the prerequisites set by regulations (such as implementing sufficient capital injection), Enter into a compliant professional liability insurance PII agreement), GFSC officially issues DLT provider license.
The fifth stage: Annual review and ongoing compliance obligations
by law every year 3 moon 31 Pay the annual supervision fee before. A statutory auditor approved by GFSC must be engaged to issue a financial audit, Submit system failure and customer complaint management reports to supervision.
7. Hong Kong Express' legal agency service for Gibraltar DLT license case
Establishment and substantive implementation of local corporations
Register a Gibraltar Private Limited Company. Assistance with leasing physical office space, Match and introduce local employees and compliance executives who meet GFSC's suitability review in accordance with the law (MLRO).
Compilation of compliance documents and risk control system
Compose contains 3 Business white paper with annual financial forecast (Whitepaper). Prepare an AML/CFT policy manual that strictly complies with the nine regulatory principles, Cybersecurity framework and liquidation plan.
GFSC defense and statutory audit docking
Fully authorized agent to submit initial proposal and formal case file to GFSC, Respond to written inquiries. Assist in connecting with public accounts of local commercial banks, and recommend GFSC-approved statutory auditors and PII insurance providers.
