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| Dimension |
Pinned 🇦🇪 ADGM (Abu Dhabi) partly open Verified 2026-08-15
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🇺🇸 United States
partly open
Verified 2026-08-15
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| Licence type | Financial Services Permission (FSP) from the FSRA to carry on one or more 'Regulated Activities' in relation to Virtual Assets under the ADGM Financial Services and Markets Regulations (FSMR), e.g. Operating a Multilateral Trading Facility (exchange), Providing Custody, Dealing in Investments as Principal/Agent (broker-dealer), Managing Assets, or Advising on Investments, each 'in relation to Virtual Assets.' The framework was originally branded 'Operating a Crypto Asset Business' (2018 Guidance) and has since been folded into the broader Virtual Asset regulated-activities regime under the 'Guidance - Regulation of Virtual Asset Activities in ADGM' (most recent version 10 June 2025). A related but separate activity/licence covers issuing Fiat-Referenced Tokens (FRTs, i.e. stablecoins). | No single federal crypto licence. Fragmented dual-layer regime: (a) State-level Money Transmitter Licence (MTL), required in 49 states (all except Montana) plus DC, applied for via NMLS (Nationwide Multistate Licensing System) under each state's money transmission statute (31 states have adopted the Money Transmission Modernization Act, MTMA, in full or part as of Feb 2026); (b) Federal FinCEN Money Services Business (MSB) registration under the Bank Secrecy Act, via FinCEN Form 107, required for any business acting as a money transmitter/administrator/exchanger of convertible virtual currency. Some states have specific regimes (e.g., NY BitLicense from NYDFS, 23 NYCRR Part 200) as an alternative/superseding requirement. |
| Regulator | Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) | No single federal crypto regulator. Federally, FinCEN (US Treasury) handles MSB registration and BSA/AML oversight. At the state level, each state's banking/financial-services department (e.g., NYDFS in New York, DFPI in California) issues and supervises money transmitter licences via NMLS. The SEC and CFTC separately assert jurisdiction over certain crypto activities (securities/commodities), the allocation of that jurisdiction is the subject of the pending CLARITY Act. |
| Capital requirement | ADGM (Abu Dhabi) capital requirement is included in the £349 pass. | United States capital requirement is included in the £349 pass. |
| Timeline to authorisation | ADGM (Abu Dhabi) timeline to authorisation is included in the £349 pass. | United States timeline to authorisation is included in the £349 pass. |
| Local substance | ADGM (Abu Dhabi) local substance is included in the £349 pass. | United States local substance is included in the £349 pass. |
| Application cost | ADGM (Abu Dhabi) application cost is included in the £349 pass. | United States application cost is included in the £349 pass. |
| Ongoing cost | ADGM (Abu Dhabi) ongoing cost is included in the £349 pass. | United States ongoing cost is included in the £349 pass. |
| Passporting | ADGM (Abu Dhabi) passporting is included in the £349 pass. | United States passporting is included in the £349 pass. |
| MiCA CASPs approved | ADGM (Abu Dhabi) mica casps approved is included in the £349 pass. | United States mica casps approved is included in the £349 pass. |
| Key restrictions | ADGM (Abu Dhabi) key restrictions is included in the £349 pass. | United States key restrictions is included in the £349 pass. |
| Recent changes | June 10, 2025: FSRA implemented major amendments, shifted from FSRA pre-approval for Virtual Assets to a notification-based process built on applicant self-assessment; introduced express prohibition on privacy tokens and algorithmic stablecoins; revised capital requirements and fees for VA firms; added product-intervention power for virtual assets. September 2025 (Abu Dhabi Finance Week): FSRA published Consultation Paper No. 10 of 2025 proposing a staking framework. Finalised Fiat-Referenced Token (FRT) framework followed, with FEES Rulebook amendments effective 1 January 2026 (published 31 October 2025). April 29, 2026: FSRA finalised the Virtual Asset staking regulatory framework after consultation. December 2025/January 2026: Binance received FSRA approval (announced 7 December 2025) to operate its global Binance.com platform in ADGM via three regulated entities, described as the first global platform-level licence of this kind under the ADGM framework, operations beginning 5 January 2026. On 7 Jul 2026 the FSRA granted a Financial Services Permission to BTCS (Middle East), the Abu Dhabi subsidiary of Bitcoin Suisse, covering spot trading in accepted virtual assets, institutional custody and derivatives for institutional and professional clients. On 23 July 2026 the FSRA recognised Tether Gold (XAUT) as an Accepted Spot Commodity in ADGM, a spot-commodities recognition distinct from the virtual-asset regulated activities, allowing appropriately permissioned firms to offer the token. | The GENIUS Act's 18 July 2026 deadline for federal implementing rules passed with no agency having finalised a rule: the OCC, FDIC, NCUA and Treasury (with FinCEN and OFAC) have issued proposed rules since December 2025, the Federal Reserve joined a five-agency customer identification proposal on 18 June 2026, and on 27 July 2026 the OCC sought approval for stablecoin issuer application forms (comments due 25 September 2026). The Act sets no penalty for the missed deadline; it takes effect on the earlier of 18 January 2027 or 120 days after final rules. The CLARITY Act remains stalled in the Senate: reported by the Banking Committee on 1 June 2026 with a substitute amendment, no cloture motion filed and no floor vote expected before the August recess; Senate Republicans circulated revised negotiating text on 22 July 2026. The SEC's three planned crypto rulemakings (token issuance safe harbour, broker-dealer capital and custody amendments, market structure) remained unpublished as of late July 2026. |
| Difficulty rating | ADGM (Abu Dhabi) difficulty rating is included in the £349 pass. | United States difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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