Crypto AML jurisdiction snapshot

Regulatory status: Crypto regulation in the US is fragmented across federal and state lines and multiple federal regulators depending on the activity involved. FinCEN regulates crypto exchangers and administrators as Money Services Businesses (MSBs) for AML purposes at federal level, while the SEC and CFTC assert jurisdiction over crypto-assets that qualify as securities or commodity derivatives respectively. Separate state laws also apply and can materially change a business's obligations — most notably New York's BitLicense regime, but many other states operate their own money transmitter licensing requirements for crypto businesses serving customers there.

Licensing required: Depends on activity and on which states are served.

Licensing overview: Federal MSB registration with FinCEN is required for most exchangers. In addition, state money transmitter or virtual currency licences (such as NY's BitLicense) are typically required on a state-by-state basis, making the practical licensing footprint highly dependent on which US states a firm intends to serve — a business operating nationally may need to hold licences in dozens of individual states.

Regulator and legislation: FinCEN (AML/MSB, federal), SEC (securities), CFTC (derivatives/commodities), NYDFS and other state regulators (state-level licensing) · Bank Secrecy Act (FinCEN MSB registration); NY Financial Services Law (BitLicense); other state money transmitter statutes

Regulatory status: The Financial Conduct Authority (FCA) has supervised cryptoasset firms for AML/CTF purposes since January 2020 under the Money Laundering Regulations, requiring registration before a firm can operate. The UK is also preparing a broader, dedicated crypto-specific regulatory regime beyond the current AML-only registration — covering conduct, market abuse, and stablecoin issuance — which is being phased in progressively as part of the government's wider plan to regulate cryptoassets under the Financial Services and Markets Act framework.

Licensing required: Yes (current AML registration), with a wider regime being introduced.

Licensing overview: MLR registration requires a full application demonstrating AML/CTF systems and controls; the FCA has a notably high scrutiny bar and a significant proportion of applications are withdrawn or refused. Firms should also track the incoming broader cryptoasset regime, which will introduce additional conduct-based requirements beyond the current AML registration.

Regulator and legislation: Financial Conduct Authority (FCA) · Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017; broader cryptoasset regime forthcoming under the Financial Services and Markets Act 2023

Regulatory status: Canada regulates virtual currency dealers as Money Services Businesses (MSBs) under FINTRAC, the federal AML/CTF regulator. Registration with FINTRAC is mandatory for entities dealing in virtual currency as part of their business. Separate provincial securities laws and other regulations may also apply — Canada's securities regulation is administered at the provincial rather than federal level, so a crypto business's obligations can vary depending on which provinces it operates in or serves.

Licensing required: Yes (federal MSB registration), with provincial requirements potentially also applying.

Licensing overview: MSB registration with FINTRAC is required at federal level; firms should also check provincial securities registration requirements in each province where they have customers, as these are administered separately from the federal AML regime.

Regulator and legislation: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada); provincial securities regulators where applicable · Proceeds of Crime (Money Laundering) and Terrorist Financing Act

Regulatory status: Switzerland does not operate a single standalone crypto register or licence. FINMA, the integrated financial regulator, authorises crypto activity under existing licence categories — including a dedicated FinTech licence and DLT trading facility authorisation — depending on the activity involved. AML supervision for many crypto firms that are not otherwise prudentially supervised runs through FINMA-recognised self-regulatory organisations (SROs) such as VQF and SO-FIT, rather than direct FINMA registration.

Licensing required: Depends on activity.

Licensing overview: The correct licensing route depends heavily on the specific activity — a firm may need a banking licence, a FinTech licence, DLT trading facility authorisation, or simply SRO membership for AML purposes if no other licence applies.

Regulator and legislation: FINMA (Swiss Financial Market Supervisory Authority); FINMA-recognised SROs (e.g. VQF, SO-FIT) for AML-only firms · Anti-Money Laundering Act (AMLA); Financial Institutions Act; DLT Act (2021 amendments)

Regulatory status: The Monetary Authority of Singapore (MAS) licenses providers of Digital Payment Token (DPT) services under the Payment Services Act. MAS is Singapore's integrated central bank and financial regulator, and maintains a live, searchable public directory of all licensed financial institutions, including DPT service providers, making counterparty verification straightforward compared to many jurisdictions.

Licensing required: Yes.

Licensing overview: Applicants apply for a licence under the relevant Payment Services Act category; MAS has taken a deliberately selective approach to approvals, and the bar for a successful application is high relative to some other Asian jurisdictions.

Regulator and legislation: Monetary Authority of Singapore (MAS) · Payment Services Act

Regulatory status: Hong Kong's Securities and Futures Commission (SFC) operates a mandatory licensing regime for Virtual Asset Trading Platforms (VATPs) under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, in force since June 2023. The regime applies to centralised trading platforms operating in Hong Kong or actively marketing to Hong Kong investors, whether based locally or abroad, and Hong Kong has been actively expanding its licensed VATP base — reaching around 47 licensed platforms by April 2026. Hong Kong is also preparing a broader licensing regime extending beyond trading platforms to cover virtual-asset dealing, custody, advisory, and asset management activities, with legislative proposals expected before the Legislative Council in 2026.

Licensing required: Yes (for trading platforms currently), expanding to other activity types.

Licensing overview: VATP applicants undergo a comprehensive SFC review covering custody standards (Hong Kong imposes one of the highest cold-storage requirements of any major regulator, at a minimum 98% of client assets), AML/CFT systems, governance, and fit-and-proper assessment of responsible officers. Firms conducting or planning to conduct dealing, custody, advisory, or asset management activities involving virtual assets should track the incoming broader regime closely, as it will introduce new licensing obligations beyond the current VATP-only regime.

Regulator and legislation: Securities and Futures Commission (SFC), in consultation with the Hong Kong Monetary Authority for bank-affiliated entities · Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), as amended by the Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Ordinance 2022

Regulatory status: Australia requires digital currency exchanges to register with AUSTRAC, the federal AML/CTF regulator, but AUSTRAC does not publish its Digital Currency Exchange Register as a public searchable database — verification of a firm's registration status must be done by contacting AUSTRAC directly. Separately, ASIC regulates crypto-assets that constitute financial products, requiring an Australian Financial Services Licence (AFSL) in those cases.

Licensing required: Depends on activity.

Licensing overview: DCE registration with AUSTRAC is required for exchange-type activity; an AFSL from ASIC may additionally be required if the crypto-asset or service constitutes a financial product under Australian law.

Regulator and legislation: AUSTRAC (AML/CTF, DCE registration); ASIC (financial products, AFSL) · Anti-Money Laundering and Counter-Terrorism Financing Act 2006; Corporations Act 2001 (where AFSL applies)

Regulatory status: Dubai (excluding the DIFC financial free zone) operates its own dedicated virtual-asset regulator, the Virtual Assets Regulatory Authority (VARA), established specifically to license and supervise crypto-asset activity in the emirate. This sits alongside separate regimes in the DIFC (regulated by the DFSA) and Abu Dhabi Global Market (regulated by the FSRA) — the UAE does not have a single unified federal crypto licensing regime, and firms should confirm which zone's rules apply to their intended activity.

Licensing required: Yes.

Licensing overview: VARA operates a categorised licensing system covering activities such as exchange, broker-dealer, custody and advisory services, each requiring a specific licence type under VARA's published rulebooks.

Regulator and legislation: Virtual Assets Regulatory Authority (VARA) — Dubai; note DIFC (DFSA) and ADGM (FSRA) operate separate regimes · Dubai Law No. 4 of 2022; VARA Rulebooks

Regulatory status: The Cayman Islands Monetary Authority (CIMA) registers and licenses Virtual Asset Service Providers under the Virtual Asset (Service Providers) Act. VASPs are a distinct, identifiable category within CIMA's broader register of regulated entities, and CIMA publishes periodic statistics on the number of registered VASPs.

Licensing required: Yes.

Licensing overview: VASPs register or, for higher-risk activities, obtain a full licence from CIMA, involving fit-and-proper checks, AML/CFT programme requirements, and ongoing supervisory reporting.

Regulator and legislation: Cayman Islands Monetary Authority (CIMA) · Virtual Asset (Service Providers) Act

Regulatory status: The BVI Financial Services Commission (FSC) is the territory's single financial regulator and registers Virtual Asset Service Providers under the VASP Act 2022. The FSC publishes a public list of registered VASPs directly on its website, distinct from its registers for other regulated sectors such as banking and investment business.

Licensing required: Yes.

Licensing overview: VASPs apply to the FSC for registration under the VASP Act, with requirements covering AML/CFT programmes, fitness of directors and senior management, and ongoing regulatory reporting.

Regulator and legislation: BVI Financial Services Commission (FSC) · Virtual Assets Service Providers Act, 2022

Regulatory status: The Securities Commission of The Bahamas (SCB) regulates digital assets under the Digital Assets and Registered Exchanges (DARE) Act, with a dedicated section of its website covering DARE registrants. The Central Bank of The Bahamas separately supervises banks and payment services. The SCB has indicated an integrated online search feature for registrants is under development; in the meantime, registrant and licensee lists are published directly on its site.

Licensing required: Yes.

Licensing overview: Digital asset businesses register or obtain authorisation from the SCB under the DARE Act, with requirements covering governance, AML/CFT controls, and ongoing reporting, consistent with the SCB's broader securities and funds regulatory framework.

Regulator and legislation: Securities Commission of The Bahamas (SCB); Central Bank of The Bahamas (banks/payments) · Digital Assets and Registered Exchanges Act (DARE Act)