Crypto Regulation

Global Crypto License Comparison

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This comprehensive table provides a side-by-side comparison of cryptocurrency licensing requirements across 11 major global jurisdictions. It analyzes how clearly each regulatory framework addresses critical safeguards for digital asset custodians, cryptocurrency exchanges, and related service providers. Use this resource to quickly assess the regulatory strengths and compliance gaps across different crypto licensing regimes worldwide.

Scoring Legend: 0 = missing · 1 = vague/voluntary · 2 = mandatory but qualitative · 3 = mandatory & explicit
Comparison of cryptocurrency licensing requirements showing regulatory authorities, compliance scores for insurance, backup keys, control of keys, operations/audit, bankruptcy remote protection, asset segregation, cold/hot wallet rules, and AML/KYC requirements across 11 major jurisdictions including Hong Kong, France, EU, US, Singapore, New York, UAE and others.
License & Jurisdiction Regulatory Authority Overall Score Insurance Coverage Backup Key Storage Key Control Authority Operations & Auditing Bankruptcy Protection Asset Segregation Cold/Hot Wallet Rules AML/KYC Compliance
Hong Kong TSCP Companies Registry, Hong Kong 21% 0 0 0 2 0 0 0 3
France DASP Autorité des Marchés Financiers (AMF) 42% 2 0 2 2 0 1 0 3
EU MiCA European Securities and Markets Authority (ESMA) 67% 0 2 3 3 3 3 0 2
US SPBD Financial Industry Regulatory Authority (FINRA) 50% 0 2 3 2 0 3 0 2
Singapore MPI Monetary Authority of Singapore (MAS) 33% 0 0 2 2 0 1 0 3
NY BitLicense NY Dept. of Financial Services (DFS) 58% 2 2 3 2 0 2 0 3
South Dakota Custodian South Dakota Division of Banking 33% 3 0 0 2 0 0 0 3
UAE VARA Virtual Asset Regulatory Authority (VARA) 83% 2 3 3 2 3 3 1 3
Spain VASP Banco de España (Bank of Spain) 8% 0 0 0 0 0 0 0 2
National Bank (OCC) Office of the Comptroller of the Currency (OCC) 25% 2 0 0 2 0 0 0 2
Ireland VASP Central Bank of Ireland 21% 0 0 0 2 0 0 0 3
Important Disclaimer: This comparison table is a work in progress and for informational purposes only. Scoring is based on available regulatory documentation and public sources, and may be updated as new information becomes available. All assessments represent opinions only and should not be relied upon as official risk ratings or compliance advice. For specific regulatory guidance, consult qualified legal professionals in each jurisdiction.

Official Sources: Each license name in the table links directly to the official regulatory authority website. Click on any jurisdiction name to access authoritative information and regulatory guidance for that specific license type.

Detailed Column Explanations

Overall Score: Aggregate compliance score indicating how clearly each licensing regime defines regulatory requirements. This is not a risk assessment or compliance rating.
Insurance Coverage: Requirements for mandatory insurance policies or surety bonds that protect client funds against operational losses, theft, or security breaches.
Backup Key Storage: Legal obligations to create, maintain, and securely store backup copies or cryptographic shards of private signing keys for business continuity.
Key Control Authority: Regulations governing signing authority, including multi-signature requirements, restrictions on key outsourcing, and exclusive control provisions.
Operations & Auditing: Mandatory security audits, penetration testing requirements, operational assessments, and ongoing regulatory reporting obligations.
Bankruptcy Protection: Legal safeguards ensuring client cryptocurrency assets remain protected and recoverable if the licensed entity becomes insolvent.
Asset Segregation: Requirements to maintain clear separation between client digital assets, the firm's proprietary holdings, and assets belonging to different clients. Learn more about custodian standards.
Cold/Hot Wallet Rules: Specific mandates for cold storage percentages, hot wallet operational procedures, and security protocols for cryptocurrency storage infrastructure.
AML/KYC Compliance: Customer due diligence requirements, identity verification procedures, transaction monitoring obligations, and record-keeping for anti-money laundering compliance.

Frequently Asked Questions About Crypto Licenses

Which cryptocurrency license has the strongest regulatory requirements?

Based on our analysis, the UAE VARA license scores highest at 83%, followed by EU MiCA at 67%. These licenses provide the most comprehensive coverage across insurance, key management, asset segregation, and operational requirements. However, regulatory strength should be evaluated based on your specific business needs and risk profile.

What is the difference between crypto licenses in different jurisdictions?

Crypto licenses vary significantly across jurisdictions in their approach to key management, insurance requirements, asset segregation, and operational oversight. Some focus heavily on AML/KYC compliance (like Hong Kong TSCP), while others provide comprehensive custody protections (like EU MiCA and UAE VARA). The regulatory landscape reflects each jurisdiction's priorities for consumer protection and financial stability.

How do I choose the right cryptocurrency license for my business?

License selection depends on your business model, target markets, operational requirements, and risk tolerance. Consider factors like regulatory clarity, ongoing compliance costs, market access, and specific requirements for your services (custody, exchange, payment processing). Review the specific regulatory authorities listed in our comparison (such as AMF for France, MAS for Singapore, or VARA for UAE) and consult with qualified legal and regulatory experts familiar with each jurisdiction's requirements.

Which jurisdictions require mandatory insurance for crypto businesses?

South Dakota Custodian license has the strongest insurance requirements (score 3), while France DASP, NY BitLicense, UAE VARA, and National Bank (OCC) have moderate insurance requirements (score 2). Many other jurisdictions currently lack specific insurance mandates for cryptocurrency businesses, representing a potential regulatory gap.