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| Dimension |
Pinned 🇧🇭 Bahrain partly open Verified 2026-07-02
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🇺🇸 United States
partly open
Verified 2026-07-03
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| 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. | 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 | Central Bank of Bahrain (CBB) | 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 | Bahrain capital requirement is locked. Unlock with the £349 pass. | United States capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Bahrain timeline to authorisation is locked. Unlock with the £349 pass. | United States timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Bahrain local substance is locked. Unlock with the £349 pass. | United States local substance is locked. Unlock with the £349 pass. |
| Application cost | Bahrain application cost is locked. Unlock with the £349 pass. | United States application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Bahrain ongoing cost is locked. Unlock with the £349 pass. | United States ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Bahrain passporting is locked. Unlock with the £349 pass. | United States passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Bahrain mica casps approved is locked. Unlock with the £349 pass. | United States mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Bahrain key restrictions is locked. Unlock with the £349 pass. | United States key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | CONFIRMED: 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), a more permissive stance than many other jurisdictions. This confirms the '2025 stablecoin module' claim. Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025. | GENIUS Act (stablecoin regulation): PASSED and SIGNED INTO LAW - House passed 17 July 2025, signed by the President 18 July 2025. Establishes a federal framework for 'payment stablecoins': permitted issuers must be a subsidiary of an insured depository institution, a federally-qualified nonbank issuer, or a state-qualified issuer; mandates 100% reserve backing in liquid assets with monthly public disclosures, no rehypothecation (limited exceptions), explicit BSA/AML obligations, a ban on deceptive marketing claims, and mandatory technical capability to freeze/seize/burn stablecoins under lawful order. Implementing rules: FinCEN/OFAC issued a joint Notice of Proposed Rulemaking on 10 April 2026 (Federal Register 2026-06963), comment period closed 9 June 2026; statutory deadline for the final rule is 18 July 2026, with enforcement no later than 18 Jan 2027. No final rule confirmed published as of 3 July 2026. CLARITY Act (market structure, SEC/CFTC jurisdiction split): STILL PENDING. Passed the House 17 July 2025 (294-134); Senate Banking Committee advanced its version 15-9 on 14 May 2026; sits unchanged on the Senate Legislative Calendar (Calendar No. 423) since 1 June 2026. Still requires reconciliation with the Senate Agriculture Committee's parallel bill (S. 3755, advanced 29 Jan 2026 on a party-line vote), a 60-vote Senate floor vote (needs roughly 7 Democratic crossover votes, none firmly committed), House-Senate reconciliation, and presidential signature. A bipartisan ethics-provision amendment was rejected 13-11 at the 14 May markup and related negotiations collapsed in June 2026. Independent passage-odds trackers show CLARITY Act odds falling from roughly 74% in early June to 44-50% by early July 2026, reflecting a tightening legislative calendar. |
| Difficulty rating | Bahrain difficulty rating is locked. Unlock with the £349 pass. | United States difficulty rating is locked. Unlock with 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.