Concept
An offshore crypto licence is a licence or registration that the regulator of an offshore financial centre grants to a virtual asset service provider (VASP): an exchange, custodian, broker, converter or token issuer.
In the Cayman Islands the status is granted by the Cayman Islands Monetary Authority (CIMA) under the Virtual Asset (Service Providers) Act; in the British Virgin Islands (BVI) by the Financial Services Commission (FSC) under the Virtual Assets Service Providers Act 2022; in Bermuda by the Bermuda Monetary Authority (BMA) under the Digital Asset Business Act 2018 (DABA); and in Seychelles by the Financial Services Authority (FSA) under the Virtual Asset Service Providers Act 2024.
Cayman registers providers and licenses only custody and trading platforms, the BVI rely on registration alone, and Bermuda and Seychelles issue licences. In all four the status works from the jurisdiction itself; EU and UK law decides whether its holder may serve clients there.
Why a separate status is needed
All four statutes prohibit virtual asset business in or from within the jurisdiction without a status. In three of them, by statute or by the regulator's reading, the prohibition also reaches companies serving foreign clients:
- a BVI company that provides such services outside the BVI, or holds itself out as able to, is deemed to be doing so from within the Virgin Islands (VASP Act 2022 s.5(4));
- a company incorporated in Bermuda that carries on digital asset business is treated as doing so in Bermuda, wherever its clients are, unless a ministerial order provides otherwise (DABA s.4(1)–(3));
- the FSA treats as operating “from Seychelles” a company managed and controlled from there, affiliated with a company physically present there, or providing the listed services abroad (FSA guidance of 19.12.2024).
A BVI, Bermuda or Seychelles company (see “Offshore Companies”) therefore cannot run a crypto business without a status even if all its clients are foreign. As the FSA reminded in Circular No. 5 of 14.08.2026, incorporating a Seychelles international business company (IBC) confers no regulatory status; the company layer is covered in “Seychelles IBC”.
What the status does not give
Key parameters
The parameters come from statutes, regulations, regulators' documents and registers at 30.09.2026.
| Parameter | Cayman Islands | BVI | Bermuda | Seychelles |
|---|---|---|---|---|
| Regulator and law | CIMA; VASP Act (2024 Revision) as amended by Act 22 of 2024 | FSC; VASP Act 2022, in force since 01.02.2023 | BMA; DABA 2018, in force since 10.09.2018 | FSA; VASP Act 2024, in force since 01.09.2024 |
| Status and classes | Registration; licence for custody and trading platforms since 01.04.2025 | Registration only: general service, custody, exchange | Class F (full), M (modified) or T (test) licence | Licence: wallet, exchange, broking, investment provider; ICOs and NFTs registered |
| Capital | No statutory minimum; a licensee holds the highest of risk-based capital, six months' fixed overheads and a CIMA-set amount | No minimum in the Act; financial soundness and initial capital in the business plan | Net assets from $100,000 (F, M) and $10,000 (T), or an amount the BMA sets | US$25,000–100,000 by service; from year three, per FSA guidance, 2.5% of annual turnover |
| Regulatory fees | Registration: CI$1,000 plus CI$1,500–15,000 a year; licence: CI$5,000 plus CI$30,000 or 100,000 on grant | Application US$5,000–10,000; on approval and yearly US$7,500, 15,000 (custody) or 25,000 (exchange) | Application $2,266 (F, M) or $1,000 (T); on grant and yearly $15,000 to $450,000, Class T $1,000 | Application 75,000 Seychelles rupees (SCR); yearly SCR 75,000 plus SCR 75,000–375,000 by service |
| People and presence | At least three directors, at least one independent; registered office; local auditor for licensees | At least two individual directors; resident director if the FSC requires; authorised representative; local address | Head office in Bermuda for F and M; senior representative for every licensee | Resident director, fully staffed office, board and management meetings in Seychelles |
| Client assets | Custodian segregates them in trust or bankruptcy-remote accounts; fiat with a regulated bank | Client-asset handling set out in the application; extra conditions for custody | Insurance commensurate with the business (F, M); custodial wallets a separate licensable activity | Reserves of 100% of liabilities to clients; liability and client-asset insurance |
| Travel rule | Part 10A of the AML Regulations since 01.07.2022; no value threshold | AML Code s.41C; corporate penalty up to US$80,000 | Wire transfer rules of the Proceeds of Crime Regulations 2008; payee verified on cross-border transfers over $1,000 | AML/CFT Act ss.45B–45G; no threshold, transfers may be held |
| Register and transition | 18 registered VASPs at Q4 2025; CIMA does not publish a licensee count | Existing providers had six months from 01.02.2023 to apply | 53 entries: 28 F, 17 M, 7 T and one without a class | No licence shown as granted; 17 entries of 8 companies under assessment |
Under the travel rule in Cayman and Seychelles, the originating VASP collects the parties' names, account or wallet details or a transaction reference and the originator's details, verifies the originator before the transfer and passes the data to the beneficiary VASP. The international standard is covered in “Travel Rule” and “The FATF”.
Cayman Islands: registration and licence
Under s.4(1) of the VASP Act, virtual asset services may be provided in or from within the Cayman Islands only with a registration, a VASP licence (required for custody and trading platforms) or a waiver for a person already supervised by CIMA under another law. The sandbox licence of up to one year that the Act also provides for is not a working entry route: the 2025 commencement orders left it out of force, and CIMA's licensing policy excludes sandbox applicants.
The regime came in two phases:
- from 31.10.2020 providers had to register with or notify CIMA, and from 01.02.2021 operating without either was unlawful (CIMA FAQ);
- since 01.04.2025 custodians and trading platforms have needed licences under the 2024 amendments (Act 22 of 2024); a registered provider already doing such business had to apply within 90 days, may operate until CIMA decides if it applied in time, and has its registration cancelled once licensed.
What needs a licence
Virtual asset services under the Act are issuance and, on behalf of others, exchange for fiat or other virtual assets, transfer, custody and financial services around an issuance or sale.
| Service | Status |
|---|---|
| Custody: safekeeping or administering virtual assets or the instruments that control them | Licence |
| Trading platform: exchanging virtual assets for third parties for a fee while holding or controlling client assets or buying from sellers | Licence |
| Exchange on a client's behalf, transfers, dealer services | Registration |
| Issuing virtual assets | Registration |
A registered person may not state or imply that it is licensed, and an unregistered person, including an applicant, may not claim CIMA regulation or authorisation. Only legal entities qualify: a Cayman company, partnership, LLC, LLP or a foreign company registered under Part IX of the Companies Act; since 2024 CIMA may not grant an individual a registration, licence or waiver. The company layer is covered in “Cayman Islands Company”.
CIMA requirements
| Requirement | Content |
|---|---|
| Directors | At least three, including at least one independent director without a vested interest |
| Fitness and propriety | Fit and proper test for shareholders or beneficial owners, directors and senior officers; senior officers need CIMA's prior approval |
| Presence | Registered office in the Islands; a licence applicant names a Cayman-practising auditor approved by CIMA |
| Business plan | Physical location of operations and customer base by jurisdiction |
| Licensee capital | Highest of risk-based capital, six months' fixed overheads and a CIMA-set amount, plus any buffer required; reviewed at least annually |
| Client assets | Segregated from the custodian's and its affiliates' assets; client fiat with a bank regulated by CIMA or in a jurisdiction that is not high-risk |
CIMA sets no staffing quota (licence application form, SL 19 of 2025). The VASP Act sets no fixed minimum capital; CIMA weighs adequate capital and cybersecurity when licensing, and the formula for custodians and platforms is in the CIMA Rule (February 2026 version). Vetting of owners and managers is covered in “Qualifying Holdings and Fit & Proper”.
Fees and statistics
Fees are set in Cayman dollars (CI$) by SL 19 of 2025.
| Status | Application | Grant | Annual |
|---|---|---|---|
| Registration (other than issuance) | CI$1,000 | CI$1,500 or 5,000 with revenue below 500,000; CI$5,000 or 15,000 above | Same amounts |
| Custodian licence | CI$5,000 | CI$30,000 | CI$30,000, 60,000 or 120,000 with revenue below 2 million, 2–10 million or 10 million and above |
| Trading platform licence | CI$5,000 | CI$100,000 | CI$50,000, 100,000 or 200,000 with revenue below 5 million, 5–20 million or 20 million and above |
The higher registration fee applies to services offered to persons outside the Islands. A Cayman-controlled local company pays one tenth of licence grant and renewal fees. At CIMA's conversion of CI$1,000 to US$1,219.50, a platform licence costs about US$121,950 on grant; the regulations do not name the currency of the revenue bands.
CIMA statistics counted 18 registered VASPs at Q4 2025, 3 with trading platforms and 7 with custody; they do not show how many licences have been granted since 01.04.2025.
The SIBA boundary and tokenised funds
A VASP may do securities investment business only with a status under the Securities Investment Business Act (SIBA) or an exemption; since 01.01.2025 CIMA must exempt from SIBA a trading platform whose securities business uses virtual assets only (the broker side is covered in “Offshore Broker Licences”). Act 4 of 2026, assented to on 19.03.2026, took digital tokens of tokenised mutual and private funds out of “virtual asset issuance” (see “Cayman Fund”).
BVI: FSC registration
Under the VASP Act 2022, in force since 01.02.2023, virtual asset services may be provided in or from within the BVI only after registration with the FSC, and individuals may not provide them at all; the company layer is covered in “BVI Company”. Providers already operating had six months to apply and could continue until the FSC decided; a refused applicant must stop immediately unless the FSC allows an orderly wind-down.
Registration has three categories:
- general virtual assets service;
- custody, subject to the additional Part IV conditions;
- operating an exchange — a trading platform that at any point comes into custody or control of money or virtual assets — also under Part IV.
When registering an exchange, the FSC may attach conditions on its geographic area of business, the clients it may market to, the assets it may trade and listing.
People, capital and fees
| Requirement | Content |
|---|---|
| Directors | At least two individuals; the FSC may require one to be physically resident, meaning absent no more than 120 days a year |
| Fitness and propriety | FSC prior approval of every director and senior officer |
| Authorised representative | An FSC-approved BVI company, BVI partnership or individual resident in the BVI |
| Application | Physical address in the BVI, FSC-approved auditor, business plan with initial capital and three-year projections |
| Policies | Written risk assessment, anti-money laundering (AML/CFT) manual, cyber security, client-asset handling |
The Act sets no minimum capital: a VASP must stay financially sound enough to meet its liabilities as they fall due and notify the FSC if it is not, and the FSC registers an applicant only if its organisation, management and financial resources are adequate.
Fees are set in US dollars by S.I. 5 of 2023. An application costs US$5,000 for the general category and US$10,000 for custody or an exchange; the registration fee on approval, then payable each year, is US$7,500, 15,000 and 25,000 respectively. Approval of an authorised representative costs US$1,500 to apply, US$2,000 on approval and US$2,000 a year.
A registered VASP that carries on only virtual asset services does not also need a licence under the Securities and Investment Business Act or the Financing and Money Services Act.
Bermuda: BMA licence
Digital asset business may be carried on in or from within Bermuda only under a BMA licence issued under DABA; breach is an offence punishable on indictment by a fine of $250,000 or five years' imprisonment. A foreign company is caught only if it carries on the activity in or from within Bermuda. Licensable activities are:
- issuing, selling or redeeming digital assets;
- payment services using digital assets;
- operating a digital asset exchange or a digital asset derivative exchange;
- digital asset trust services;
- custodial wallet services;
- acting as a digital asset services vendor;
- digital asset lending or repo (since 2023).
Licence classes and presence
| Class | Purpose | Head office in Bermuda | Minimum net assets |
|---|---|---|---|
| F (full) | Any activities | Required | $100,000 |
| M (modified) | Activities for a period set by the BMA | Required | $100,000 |
| T (test) | Pilot or beta testing for a defined period | Not required | $10,000 |
The BMA may extend M and T periods, decide an applicant's class and set a different net asset amount for the business's nature, size and complexity. Class F and M licensees must also carry insurance commensurate with their business or agree alternative risk mitigation with the BMA.
A head office means the business is directed and managed from Bermuda, judged by where strategy, risk and operational decisions are made, where the responsible senior executives sit and where the board meets. Every licensee, Class T included, appoints a BMA-approved senior representative, who for F and M keeps an office in Bermuda.
The Act requires the business to be effectively directed by at least two persons under the oversight of non-executive directors, and the BMA asks applicants to show which staff are Bermuda-based and what share of their time the others give to Bermuda operations (the logic is covered in “Substance”).
Fees, timing and the register
The 2026 fees are set by the BMA fee schedule.
| Charge | Classes F and M | Class T |
|---|---|---|
| Application | $2,266 | $1,000 |
| Grant fee and annual fee (due by 31 March) | Lower of $450,000 and the higher of the floor and 0.075% of client receipts | $1,000 |
| Fee floor | $15,000 for most activities; $150,000 for an exchange or derivatives exchange holding client keys; $100,000 without keys and for lending or repo | Not applicable |
The BMA's Assessment and Licensing Committee meets weekly, and the BMA aims to confirm completeness within three business days and to put a complete application before it within 20 business days after the first Friday following receipt: one received by 5 p.m. on a Thursday is considered four weeks later. These service targets do not guarantee approval.
On 30.09.2026 the BMA register lists 53 digital asset businesses: 28 Class F, 17 Class M and 7 Class T licensees and one entry with no class shown. The BMA treats digital asset transmission by a payment-service provider as a wire transfer under regulations 21–31 of the Proceeds of Crime Regulations 2008 (POCR); its 2025 guidance expects Class M and T licensees to have AML policies fully compliant with the POCR, including Part 4 (the travel rule), before operating.
Seychelles: FSA licence
Basic rules of the VASP Act 2024, in force since 01.09.2024:
- virtual asset services may be provided in or from Seychelles only under an FSA licence, individuals may not provide them at all, and mining facilities and mixer or tumbler services are banned outright;
- only a Seychelles domestic company, other than an overseas company, or an IBC may apply, and a licensee under the Financial Institutions Act or the National Payment Systems Act first needs Central Bank approval;
- the licence has no fixed term, and a rejected applicant must wait six months before reapplying.
Licences cover four services: wallet providers (custody), exchanges, broking and investment providers; ICOs and NFT issuances are registered separately. The FSA may require a foreign company operating “from Seychelles” to convert or continue into a Seychelles company or IBC, or to exit the jurisdiction.
Capital, fees and substance
Capital is set by S.I. 72 of 2024 and fees by the Second Schedule to the Act.
| Service | Initial paid-up capital | Annual fee |
|---|---|---|
| Wallet provider | US$75,000 | SCR 75,000 + 300,000 |
| Exchange | US$100,000 | SCR 75,000 + 375,000 |
| Broking | US$50,000 | SCR 75,000 + 150,000 |
| Investment provider | US$25,000 | SCR 75,000 + 75,000 |
A licence application costs SCR 75,000 and an ICO or NFT registration application SCR 22,500. Capital is held separately for each licensed activity, in cash, bonds or approved securities at a Seychelles bank or a Basel II-compliant institution.
From the start of a new licensee's third year, the FSA's guidance of 20.07.2026 (para 3.5(a)) says the minimum capital “shall be equivalent to” 2.5% of annual turnover from licensed services, shown when the third annual fee is paid: US$1,000,000 of turnover means US$25,000. Neither the Regulations nor the guidance keeps the initial amount as a floor, so on their text the turnover test replaces it; the FSA does not say so expressly, and the Act lets it direct a different minimum. Providers operating on 01.09.2024 show 2.5% of turnover from the outset.
A licensee also holds reserve assets or money equal to 100% of its liabilities to clients for their assets and carries professional indemnity and client-asset cover proportionate to its risks, or an FSA-approved alternative.
The Act writes substance into the licence (ss.13–14 and the Third Schedule):
- at least one resident director, and a board of at least two natural persons;
- a fully staffed office in Seychelles with qualified staff and access to records;
- complaint handling in Seychelles;
- at least two board meetings and four management meetings a year in Seychelles.
Transition and the application queue
Providers operating on 01.09.2024 had until 31.12.2024 to file a complete application and may continue until the FSA decides; those that did not file had to stop from 01.01.2025, and new entrants must be licensed before starting. In Circular No. 14 of 19.11.2025 the FSA said it had finished triaging transitional applications, begun detailed assessment with interviews and listed recurring deficiencies:
- placeholder, cut-and-paste or AI-generated group policies;
- weak or non-independent key persons and directors;
- inadequate substance, including no resident senior management.
Such applications risk refusal or a move to the back of the queue. The FSA's service standard is three months to two years from a complete application; within 90 working days the FSA says whether an application is incomplete and so refused. As of 30.09.2026 the four licensed sections of the FSA's VASP page are empty; the assessment section lists 17 activity entries (5 wallet, 4 broking, 7 exchange, 1 investment provider) for 8 companies, each with a date of approval and the status “Assessment”.
Unlicensed business is punishable by a fine of up to SCR 5,250,000 for a company, or up to SCR 2,250,000 and 15 years' imprisonment for an individual, plus up to SCR 375,000 a day for an offence continuing after conviction. IBCs regulated abroad must disclose the authority they act under and must not imply FSA supervision (Circular No. 5 of 2026).
Contracts for difference (CFDs) on crypto-assets stay under the securities dealer licence (FSA Circular No. 3 of 28.02.2025), as a CFD involves no ownership, delivery or blockchain transfer; that licence is covered in “Offshore Broker Licences”.
Popular, but it ends badly
Each of two common schemes meets a separate legal rule:
- an exchange serves clients worldwide through an offshore company without a licence anywhere;
- an exchange obtains an offshore status and solicits clients in the EU and the UK, citing their own initiative.
The first breaches the VASP laws, and in Seychelles the FSA has applied them to a major exchange: on 26.05.2026 it announced that it had identified MX Global Ltd, a Seychelles IBC, as the operator of the MEXC exchange, found it in breach of s.5 of the VASP Act and s.5 of the IBC Act since 01.01.2025, and was initiating enforcement including referral to the competent authority. It said it could not help customers recover funds as the company holds no licence.
EU: reverse solicitation under MiCA
Under MiCA Art. 61 a third-country firm may serve an EU client without authorisation only at the client's own exclusive initiative (reverse solicitation). Any solicitation in the Union by the firm, an entity acting on its behalf or closely linked to it, by any means, removes the exemption regardless of contractual clauses or disclaimers, and the firm may not market new types of crypto-assets or services to that client. An overview is in “MiCA: EU Single Regime for Crypto-Assets”.
ESMA's Article 61 guidelines (ESMA35-1872330276-2030 of 26.02.2025) apply 60 calendar days after their publication in all EU languages, that is, from late April 2025. ESMA's compliance table of 10.07.2026 shows every EU supervisor complying except those of Poland and Romania, which are recorded as non-compliant by default pending designation of a competent authority.
MiCA has applied in full since 30.12.2024 and does not cover crypto-assets that qualify as financial instruments, so crypto CFDs fall under the investment services rules; the MiFID II analysis is in “Offshore Broker Licences”.
UK: promotions and crypto CFDs
Until 25.10.2027, UK-facing promotions by an offshore crypto business are governed by the financial promotion regime under FSMA 2000 and the FCA's Conduct of Business Sourcebook (COBS).
| Provision | What it sets |
|---|---|
| FSMA s.21 and s.25 | An unauthorised person may not promote investments unless an authorised person approves the content; promotions from abroad are caught if capable of having an effect in the UK; an offence, up to two years' imprisonment |
| FSMA s.55NA | Since 07.02.2024 an authorised firm may approve an unauthorised person's promotion only with FCA permission; exemptions for an approver in the same group or one that prepared the content (S.I. 2023/966) |
| Financial Promotion Order art. 73ZA (S.I. 2023/612) | Exemption only for unauthorised exchanges and custodian wallet providers on the FCA's money-laundering register: they may promote cryptoassets without approval; repealed from 25.10.2027 |
| COBS 4.12A | Prescribed risk warning required; bonuses, cashback, trading-volume rebates and free gifts prohibited |
| COBS 4.12A, direct offers | Only with a cooling-off period of at least 24 hours, a personalised risk warning, a client certified as high net worth, sophisticated or restricted investor, and an appropriateness assessment |
| COBS 22.6 | MiFID investment firms, third-country branches and other listed firms may not sell or market cryptoasset derivatives to retail clients, which includes approving another firm's promotion of crypto CFDs |
| FSMA s.30 and s.26 | Agreements resulting from an unlawful promotion (s.30) or breaching the general prohibition (s.26) are unenforceable against the client, who recovers money and compensation |
An offshore VASP without FCA registration falls outside art. 73ZA, so without approval by an FCA-permitted firm (an s.21 approver) or an FCA-authorised member of its own group its UK promotions are unlawful. The prescribed warning reads: “Don’t invest unless you’re prepared to lose all the money you invest. This is a high-risk investment and you should not expect to be protected if something goes wrong.”
For spot cryptoassets before 25.10.2027 the civil consequence comes from s.30, under which the court may allow enforcement if it is just and equitable; s.26 applies to regulated products such as crypto CFDs.
The Cryptoassets Regulations 2026 (S.I. 2026/102), made on 04.02.2026, remove the art. 73ZA exemption from 25.10.2027, when the new FSMA cryptoasset regime starts. According to the FCA, firms that rely on an s.21 approver and do not apply for authorisation must run off their UK cryptoasset business before 25.10.2027; the application window runs from 30.09.2026 to 28.02.2027. The 2027 regime and the test for overseas firms are covered in “The UK in 2026–2028”.
Choosing between the regimes
The choice starts with where the clients are: for the EU and the UK none of the four regimes is enough. Then come the service, staffing on the islands and timing: the FSA shows no Seychelles licence granted yet, and its service standard runs up to two years.
| Business model | Regime | What decides it |
|---|---|---|
| Custodian or trading platform | Cayman, licence | CI$30,000 or 100,000 on grant; three directors; capital under the CIMA Rule |
| Exchange for clients, transfers, dealer services | Cayman, registration; BVI, general category | CI$1,000 plus CI$1,500–15,000 a year; in the BVI US$5,000 plus US$7,500 a year |
| Exchange or custody run through a local authorised representative | BVI, custody or exchange | Resident director only if the FSC requires; no statutory minimum capital; US$15,000–25,000 a year |
| Exchange, custody or lending managed from the islands | Bermuda, Class F | Head office; net assets from $100,000; fee $15,000 to $450,000 a year |
| Pilot or beta test | Bermuda, Class T | No head office; net assets $10,000; fee $1,000; senior representative still required |
| Wallet, exchange or broker with a team on the islands | Seychelles | US$25,000–100,000, then 2.5% of turnover from year three; resident director; no licence shown as granted yet |
| Crypto CFDs | Seychelles, securities dealer | No VASP licence needed where CFDs are approved |
| Clients in the EU or the UK | None of the four | MiCA CASP authorisation; in the UK approved promotions, then FCA authorisation from 25.10.2027 |
Company and tax matters are covered in “Cayman Islands Company”, “BVI Company” and “Seychelles IBC”, the EU lists in “Offshore Companies”. “Crypto Licences by Jurisdiction” compares the EU, the UAE, Hong Kong, Singapore and other centres, “License for Rent” covers working under another firm's status, and the “Financial Licences” hub gathers the remaining regimes.
Q/A
Status and cost
How much does a VASP licence cost in Cayman?
A licence application costs CI$5,000, and the grant fee is CI$30,000 for a custodian or CI$100,000 for a trading platform (about US$121,950 at CIMA's conversion). The annual fee depends on revenue and reaches CI$120,000 and CI$200,000 respectively; a Cayman-controlled local company pays one tenth.
Does a BVI company need registration if all its clients are abroad?
Yes. A BVI company providing virtual asset services outside the BVI is deemed to do so from within the Virgin Islands, so without FSC registration it breaches the VASP Act 2022.
Has the Seychelles FSA granted any VASP licences?
As of 30.09.2026 the licensed sections of the FSA's page are empty and the FSA has announced no grant: 17 activity entries belonging to 8 companies are listed under assessment. Transitional applications are under detailed review with interviews; the service standard is three months to two years.
People and capital
What capital does a Seychelles VASP need?
On application, US$75,000 for a wallet provider, US$100,000 for an exchange, US$50,000 for broking and US$25,000 for an investment provider, held separately for each activity. From year three, under FSA guidance, the requirement equals 2.5% of annual turnover from licensed services. Reserves must also cover 100% of liabilities to clients.
Does a Bermuda test licence need an office in Bermuda?
No. Class T is exempt from the head-office requirement, and its senior representative need not keep an office in Bermuda. Every licensee still appoints a BMA-approved senior representative; Class T net assets are $10,000 and the fee is $1,000.
How many directors does a Cayman VASP need?
At least three, including at least one independent director. Shareholders or beneficial owners, directors and senior officers must be fit and proper, and senior officers need CIMA's prior approval.
EU, UK and CFDs
Can an offshore-licensed firm serve EU clients?
Only a client who came at their own exclusive initiative, and without marketing new types of crypto-assets or services to them (MiCA Art. 61). Any solicitation, including brand advertising, affiliate campaigns and influencers, removes the exemption. Serving EU clients requires CASP authorisation.
Can an offshore crypto exchange advertise in the UK?
Until 25.10.2027 such promotions are lawful only once approved by an FCA-permitted firm or an FCA-authorised member of its group, with the prescribed warning and no incentives. According to the FCA, firms that do not apply for authorisation must run off their UK cryptoasset business before that date, when the art. 73ZA exemption also ends.
Do crypto CFDs in Seychelles need a VASP licence?
No, where the securities dealer is approved for CFDs. In Circular No. 3 of 2025 the FSA placed such CFDs under the dealer licence because a CFD involves no ownership, delivery or blockchain transfer.