Global Crypto License Comparison
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.
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 |
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
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.