🇧🇭 Bahrain vs 🇰🇷 South Korea: crypto licensing compared
Decision context and regulator route
Bahrain and South Korea are commonly considered side by side for crypto authorisation. In Bahrain the route is the Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers. overseen by Central Bank of Bahrain (CBB); in South Korea it is the VASP registration (not a discretionary licence) under the Act on Reporting and Using Specified Financial Transaction Information (the 'FTRA'/AML Reporting Act, amended effective 25 Mar 2021), which requires: (1) ISMS certification from KISA (Korea Internet & Security Agency); (2) for KRW fiat on/off-ramp services, a bank-issued real-name verified account; plus fit-and-proper/AML program requirements. Layered on top since 19 July 2024 is the Act on the Protection of Virtual Asset Users (VAUPA), which adds customer-asset segregation, insurance/reserve, and market-abuse rules but does not replace the underlying FTRA registration. under Financial Services Commission (FSC), Korea's top financial policymaker; Korea Financial Intelligence Unit (KoFIU, also referred to as FIU), an FSC-subordinate unit established 2001 under the FTRA that receives and processes VASP registrations and AML reporting; day-to-day supervision/inspection is delegated to the Financial Supervisory Service (FSS), which set up dedicated Virtual Asset Supervision/Investigation bureaus (announced 29 Nov 2023). FSC retains final sanctioning authority.. The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Bahrain: verified 2026-08-15 · South Korea: verified 2026-08-15
| Dimension |
🇧🇭 Bahrain
partly open
Verified 2026-08-15
|
🇰🇷 South Korea
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers. | VASP registration (not a discretionary licence) under the Act on Reporting and Using Specified Financial Transaction Information (the 'FTRA'/AML Reporting Act, amended effective 25 Mar 2021), which requires: (1) ISMS certification from KISA (Korea Internet & Security Agency); (2) for KRW fiat on/off-ramp services, a bank-issued real-name verified account; plus fit-and-proper/AML program requirements. Layered on top since 19 July 2024 is the Act on the Protection of Virtual Asset Users (VAUPA), which adds customer-asset segregation, insurance/reserve, and market-abuse rules but does not replace the underlying FTRA registration. |
| Regulator | Central Bank of Bahrain (CBB) | Financial Services Commission (FSC), Korea's top financial policymaker; Korea Financial Intelligence Unit (KoFIU, also referred to as FIU), an FSC-subordinate unit established 2001 under the FTRA that receives and processes VASP registrations and AML reporting; day-to-day supervision/inspection is delegated to the Financial Supervisory Service (FSS), which set up dedicated Virtual Asset Supervision/Investigation bureaus (announced 29 Nov 2023). FSC retains final sanctioning authority. |
| Capital requirement | Bahrain capital requirement is included in the £349 pass. | South Korea capital requirement is included in the £349 pass. |
| Timeline to authorisation | Bahrain timeline to authorisation is included in the £349 pass. | South Korea timeline to authorisation is included in the £349 pass. |
| Local substance | Bahrain local substance is included in the £349 pass. | South Korea local substance is included in the £349 pass. |
| Application cost | Bahrain application cost is included in the £349 pass. | South Korea application cost is included in the £349 pass. |
| Ongoing cost | Bahrain ongoing cost is included in the £349 pass. | South Korea ongoing cost is included in the £349 pass. |
| Passporting | Bahrain passporting is included in the £349 pass. | South Korea passporting is included in the £349 pass. |
| MiCA CASPs approved | Bahrain mica casps approved is included in the £349 pass. | South Korea mica casps approved is included in the £349 pass. |
| Key restrictions | Bahrain key restrictions is included in the £349 pass. | South Korea key restrictions is included in the £349 pass. |
| Recent changes | In July 2025 the CBB issued a new Stablecoin Issuance and Offering (SIO) Module, added to Rulebook Volume 6, creating Bahrain's first dedicated stablecoin licensing framework. It covers issuance, minting, burning, and reserve management of single-currency stablecoins backed by BHD, USD, or other CBB-accepted fiat currencies; requires issuers to incorporate as a Bahraini B.S.C.; mandates perpetual redemption rights for holders; and explicitly permits yield-bearing stablecoins (subject to CBB-set limits). On 3 June 2026 AX Coin Bahrain B.S.C. (c), a subsidiary of Nasdaq-listed Solowin Holdings, announced it had been granted the first licence under this framework, for stablecoin issuer activities (per the issuer's announcement; a CBB press release confirming the grant is pending direct confirmation). Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025. In May 2026 the CBB restructured the approved-persons section (CRA-1.7) of the Crypto-Asset Module, regrouping its fit-and-proper, prior-approval and notification rules under relocated headings (Rulebook revision of 6 May 2026). | The 20 Aug 2026 tightening is now identifiable as Act No. 21358 (amendment to the FTRA/AML Reporting Act), promulgated 19 Feb 2026 and taking effect 20 Aug 2026. It removes the KRW 1,000,000 Travel Rule de minimis threshold and separately expands VASP entry screening: adds a statutory definition of major shareholders, extends fit-and-proper disqualification checks to major shareholders, adds financial condition, social credibility, organisational, staffing and IT review factors, and authorises KoFIU to attach conditions when accepting a VASP report. Existing registered VASPs must re-report under the amended Article 7 within 3 months of the effective date (by approximately 20 Nov 2026). Separately, a Foreign Exchange Transactions Act amendment creating cross-border VASP registration passed 7 May 2026 (effective date disputed, 2 Aug vs 2 Dec 2026). The FSC's implementing-decree package (public comment 30 March to 11 May 2026) adds entry screening for VASP re-reports: a debt-ratio ceiling of 200 per cent excluding customer deposits, a three-year clean default record, fit-and-proper tests for officers and major shareholders, and AML staffing requirements; it removes the KRW 1,000,000 Travel Rule de minimis entirely and treats cross-border transfers of KRW 10,000,000 or more to foreign VASPs or private wallets as automatically suspicious. |
| Difficulty rating | Bahrain difficulty rating is included in the £349 pass. | South Korea difficulty rating is included in the £349 pass. |
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What changed recently
🇧🇭 Bahrain (verified 2026-07-15): In July 2025 the CBB issued a new Stablecoin Issuance and Offering (SIO) Module, added to Rulebook Volume 6, creating Bahrain's first dedicated stablecoin licensing framework. It covers issuance, minting, burning, and reserve management of single-currency stablecoins backed by BHD, USD, or other CBB-accepted fiat currencies; requires issuers to incorporate as a Bahraini B.S.C.; mandates perpetual redemption rights for holders; and explicitly permits yield-bearing stablecoins (subject to CBB-set limits). On 3 June 2026 AX Coin Bahrain B.S.C. (c), a subsidiary of Nasdaq-listed Solowin Holdings, announced it had been granted the first licence under this framework, for stablecoin issuer activities (per the issuer's announcement; a CBB press release confirming the grant is pending direct confirmation). Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025. In May 2026 the CBB restructured the approved-persons section (CRA-1.7) of the Crypto-Asset Module, regrouping its fit-and-proper, prior-approval and notification rules under relocated headings (Rulebook revision of 6 May 2026).
🇰🇷 South Korea (verified 2026-08-01): The 20 Aug 2026 tightening is now identifiable as Act No. 21358 (amendment to the FTRA/AML Reporting Act), promulgated 19 Feb 2026 and taking effect 20 Aug 2026. It removes the KRW 1,000,000 Travel Rule de minimis threshold and separately expands VASP entry screening: adds a statutory definition of major shareholders, extends fit-and-proper disqualification checks to major shareholders, adds financial condition, social credibility, organisational, staffing and IT review factors, and authorises KoFIU to attach conditions when accepting a VASP report. Existing registered VASPs must re-report under the amended Article 7 within 3 months of the effective date (by approximately 20 Nov 2026). Separately, a Foreign Exchange Transactions Act amendment creating cross-border VASP registration passed 7 May 2026 (effective date disputed, 2 Aug vs 2 Dec 2026). The FSC's implementing-decree package (public comment 30 March to 11 May 2026) adds entry screening for VASP re-reports: a debt-ratio ceiling of 200 per cent excluding customer deposits, a three-year clean default record, fit-and-proper tests for officers and major shareholders, and AML staffing requirements; it removes the KRW 1,000,000 Travel Rule de minimis entirely and treats cross-border transfers of KRW 10,000,000 or more to foreign VASPs or private wallets as automatically suspicious.
Quick answers
Who regulates crypto licensing in Bahrain and South Korea?
Bahrain: Central Bank of Bahrain (CBB). South Korea: Financial Services Commission (FSC), Korea's top financial policymaker; Korea Financial Intelligence Unit (KoFIU, also referred to as FIU), an FSC-subordinate unit established 2001 under the FTRA that receives and processes VASP registrations and AML reporting; day-to-day supervision/inspection is delegated to the Financial Supervisory Service (FSS), which set up dedicated Virtual Asset Supervision/Investigation bureaus (announced 29 Nov 2023). FSC retains final sanctioning authority..
What licence do you need in Bahrain compared with South Korea?
In Bahrain the authorisation route is Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers.; in South Korea it is VASP registration (not a discretionary licence) under the Act on Reporting and Using Specified Financial Transaction Information (the 'FTRA'/AML Reporting Act, amended effective 25 Mar 2021), which requires: (1) ISMS certification from KISA (Korea Internet & Security Agency); (2) for KRW fiat on/off-ramp services, a bank-issued real-name verified account; plus fit-and-proper/AML program requirements. Layered on top since 19 July 2024 is the Act on the Protection of Virtual Asset Users (VAUPA), which adds customer-asset segregation, insurance/reserve, and market-abuse rules but does not replace the underlying FTRA registration.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Bahrain vs South Korea comparison?
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