How to Get a Crypto Licence —
7 Steps from Decision to Approval

Jurisdiction selection is the most consequential decision in the licensing process. The wrong choice can mean 12 months wasted, hundreds of thousands spent, or a licence that doesn't actually allow you to serve your target customers.

The key variables to weigh are: (1) Market access — does the licence allow you to serve your target customers? (2) Capital requirements — how much do you need in the company? (3) Timeline — when do you need to be live? (4) Credibility — does the licence satisfy your institutional partners and investors? (5) Cost — total first-year cost including government fees, advisory, and running costs.

Before filing anything, you need a precise definition of what services you will offer. Regulators are not interested in vague descriptions — they want to understand exactly what you do, who your clients are, how transactions flow, and what risks arise.

Key questions to answer: Will you hold client funds (custody) or just execute orders? Will you offer services to retail clients or professionals only? Will you accept fiat deposits? What geographic markets will you serve? What is your transaction volume in Year 1, 2, and 3?

This is not just a compliance exercise — your answers determine which licence type you need (affecting capital requirements by 3x or more) and which jurisdictions are viable.

Every jurisdiction requires the applicant to be a locally incorporated entity. You cannot apply for a Polish crypto licence through a Cayman Islands holding company — you need a Polish sp. z o.o. For Singapore, you need a Singapore Pte. Ltd. For UAE VARA, you need a Dubai-registered entity.

Local incorporation typically takes 3–10 business days for straightforward company setups (longer if there are complications with bank accounts). Key steps: draft articles of association, appoint directors, deposit share capital, register with the local companies registry, and obtain tax identification numbers.

Critically, many jurisdictions also require real operational substance — not just a registered address, but a physical office, local key management, and genuine business operations. This is particularly important for Singapore MAS, UAE VARA, and most EU MiCA applications. Plan substance requirements before incorporation.

This is the step most applicants underestimate — and the most common cause of application rejection or delay. Regulators do not want to see generic AML policy templates downloaded from the internet. They want policies tailored to your specific business model, product, and risk profile.

A complete AML/KYC program includes: (1) a Business-Wide Risk Assessment (BWRA), (2) Customer Due Diligence (CDD) procedures for standard, simplified, and enhanced scenarios, (3) a transaction monitoring policy with clear red flags and escalation procedures, (4) Suspicious Activity Report (SAR/STR) filing procedures, (5) Travel Rule compliance procedures, (6) sanctions screening policies, (7) staff training program, (8) annual AML audit procedure.

You also need to appoint an Anti-Money Laundering Compliance Officer (AMLCO / MLRO). In many jurisdictions (Poland, UAE, UK), this person must be locally resident. Their CV, qualifications, and criminal background check are submitted as part of the application.

The application package varies significantly by jurisdiction, but typically includes: the completed application form, corporate documents (articles of association, certificate of incorporation, register of directors and shareholders), KYC packages for all directors, key managers, and ultimate beneficial owners (UBOs), a business plan / programme of operations, AML/KYC policy suite, financial projections (3–5 years), evidence of capital adequacy, technology documentation (for custodians and exchanges), and a description of outsourcing arrangements.

For premium jurisdictions like Singapore MAS or UAE VARA, the business plan is often a 60–100 page document covering governance, risk management, technology architecture, and regulatory compliance frameworks. At this level, specialised advisors who know current regulator expectations pay for themselves many times over.

Once you submit, the regulator's clock starts. Most regulators acknowledge receipt within 5–10 business days and may request additional information (RFI / clarification request) before formally starting the review clock. Respond to all RFIs promptly and completely — partial responses reset the clock.

The review period varies: 4–8 weeks for Poland VASP registration; 3 months for MiCA CASP (mandated maximum); 6–12 months for MAS; no maximum for some UAE processes. During this period, maintain close communication with your in-country legal representatives. Do not make material changes to your business plan or ownership structure without notifying the regulator.

Many regulators now request in-person meetings with company principals as part of the review. For UAE VARA and Singapore MAS, these meetings are standard and the outcome can significantly influence the approval decision. Prepare thoroughly — treat it as a board-level regulatory interview.

Getting the licence is the beginning, not the end. Every jurisdiction imposes ongoing compliance obligations, and regulators are increasingly active in supervising licensed entities — not just approving them. Failure to meet ongoing requirements can result in licence suspension, revocation, and personal liability for directors.

Standard ongoing obligations include: transaction monitoring and SAR filing, periodic financial and compliance reporting to the regulator, annual AML audit by an independent compliance professional, maintaining and updating AML/KYC policies as regulations evolve, notifying the regulator of material changes (ownership, business model, key staff), Travel Rule compliance for all applicable transfers, and annual audited accounts.

For EU MiCA CASPs specifically, there are additional ongoing requirements around client asset safeguarding, complaint handling, conflicts of interest management, and market abuse prevention. Build these into your compliance budget from day one.