A financial services licence in the Gelephu Mindfulness City is granted by a young regulator working from a new Act and a rulebook still being filled in, so how an application is framed matters as much as the business behind it. Basnet Law Pte. Ltd. is the first law firm incorporated in GMC. We advise banks, asset managers, brokers, insurers and fintechs on obtaining and keeping a Financial Services Licence from the Gelephu Financial Services Office (GFSO) under the Financial Services Act 2025 and the GEN Rulebook 2026. This page explains what the licence involves and how we take a firm through it.
How we help
- Mapping your business against the regulated activities, from Dealing in Investments as Principal through Managing Assets to Managing a Collective Investment Fund.
- Financial Services Licence applications under the Act and the GEN Rulebook, including the Threshold Conditions every applicant must meet.
- Approved Person applications for the Controlled Functions, and the appointments the GEN Rulebook makes mandatory.
- Governance, systems and controls under the GEN Rulebook, including whistleblowing policies.
- Variations of permission, waivers and changes of control once you are licensed.
- Financial promotion compliance and the rules on misleading statements.
- Representative Office set-up under the GEN Rulebook.
How GMC financial services law works, in plain terms
The Financial Services Act 2025 has applied in GMC since 26 December 2024. Its General Prohibition is the starting point: "No person may carry on a Regulated Activity by way of business in GMC, or purport to do so" unless they are a Licensed Firm or an Exempt Firm. A Licensed Firm is a firm holding a Financial Services Licence, and it must also stay within the terms of that licence.
An application may be made by a body corporate or a partnership. Before granting a licence the Regulator must be satisfied that the applicant will meet, and keep meeting, the Threshold Conditions set in its Rules. It can grant the licence subject to conditions, restrictions or limitations. For firms based outside GMC, the Regulator may take account of the opinion of the home regulator.
Individuals who perform Controlled Functions must be Approved Persons, and a Licensed Firm must take reasonable care to ensure that no one else performs them. The GEN Rulebook requires a GMC-incorporated Licensed Firm to have its head office and registered office in GMC, judged by where the directors, senior management and day-to-day control actually sit, not by the address on the letterhead.
The detailed rules sit in the rulebooks applied through Schedule B to the Application of Laws Act 2024: AML and Sanctions, COBS, Fund, GEN, Market Infrastructure and Prudential, all at gmc.bt/GFSO. Capital requirements are set in those rulebooks, not in the Act.
Who this is for
- International financial institutions establishing a GMC-licensed subsidiary or branch.
- Asset managers, brokers and advisers seeking a Financial Services Permission.
- Insurers, reinsurers and insurance intermediaries.
- Payment, credit and money-services businesses.
- Existing Licensed Firms facing a variation, a change of control or a supervisory enquiry.
How an engagement runs
- Perimeter and scope. We confirm which Schedule 1 activities and exclusions apply to your model and the client categories you will serve, so you apply for exactly what you need.
- Pre-application. We prepare you for the initial GFSO meeting and the business model presentation described on gmc.bt/GFSO.
- Application. We draft the application, the regulatory business plan, the governance and controls documentation and the Approved Person forms, and lodge them.
- In-Principle Approval. We manage the preconditions GFSO attaches: incorporation, bank account, capital, office and staff, until the licence is released.
- Licence and beyond. We support the notifications, regulatory returns and complaints procedures the GEN Rulebook requires once you are trading.
Frequently asked questions
Who is the financial regulator in GMC?
GFSO, the Gelephu Financial Services Office, described on gmc.bt/GFSO as the independent regulator of all financial services and virtual assets activities in GMC. The Act calls it the Regulator, and it is the body we deal with on each application.
Which roles must be approved before we can trade?
The GEN Rulebook requires a Senior Executive Officer, a Compliance Officer and a Money Laundering Reporting Officer, each held by an Approved Person at all times, plus a Finance Officer for banks and insurers. A Credit Rating Agency and a Venture Capital Fund manager have limited relief from these appointments. We prepare the Approved Person applications alongside the licence.
Can a foreign-regulated firm passport into GMC?
No. There is no passporting in the Act. A Non-GMC Firm must still be licensed, although the Regulator may have regard to the home regulator's opinion when it assesses the Threshold Conditions, and we make sure that opinion is put in front of it.
What happens if we operate without a licence?
Agreements made in breach of the General Prohibition are unenforceable against the other party, who may recover any money or property transferred and compensation. Making misleading statements to induce someone to invest is a separate contravention. We check the perimeter before you take a client.
Do we need a physical office in Gelephu?
Yes, for a GMC-incorporated Licensed Firm: the head office and registered office must be in GMC, and the GEN Rulebook guidance says an applicant that cannot satisfy this "will, on this point alone, not be considered fit and proper". We help you plan the office and staffing before the application goes in.
Talk to GMC counsel on the ground
Basnet Law Pte. Ltd. is the first law firm incorporated in the Gelephu Mindfulness City. A short conversation early in a matter usually saves time and cost later. Write to basnet@basnetgmc.com or office@basnetgmc.com with a few lines about your plans, and we will tell you plainly what is needed, how long it takes, and whether we are the right fit.
You may contact Basnet Law at basnet@basnetgmc.com or office@basnetgmc.com for any legal queries related to GMC.
