This hub collects our guides to digital asset regulation in the Gelephu Mindfulness City Special Administrative Region (GMC). Virtual assets appear in the primary statute, the Financial Services Act 2025, on the same footing as financial instruments, and the Gelephu Financial Services Office (GFSO) is described on gmc.bt/GFSO as the independent regulator of all financial services and virtual assets activities in GMC. Finance and Digital Assets is one of the eight priority industries listed on gmc.bt/about.

What this guide covers

Three features of the statute shape every crypto question in GMC. First, the core activities are defined to include virtual assets: dealing in investments as principal means buying or selling "Financial Instruments, Virtual Assets, or Spot Commodities" (Schedule 1, para. 4); providing custody includes safeguarding "Financial Instruments, Virtual Assets or, Spot Commodities belonging to another" (para. 43(1)(a)); and operating a Multilateral Trading Facility includes one on which virtual assets are traded (para. 54(1)(a)). Second, issuing a fiat-referenced token is a named regulated activity (para. 53B). Third, GFSO has a specific rule-making power for Licensed Firms conducting Regulated Activities in relation to virtual assets, spot commodities or fiat-referenced tokens, including the criteria for an "Accepted Virtual Asset" (s. 5A(1)), and a general direction power over those activities (s. 5B).

The General Prohibition in s. 16 applies to all of this: no person may carry on a Regulated Activity by way of business in GMC unless it is a Licensed Firm or an Exempt Firm.

The framework

• The GMC Digital Asset Framework: Why Virtual Assets Are a First-Class Regulated Asset Class, Not an Afterthought — the positioning piece: GFSO's remit, s. 5A, and the supplementary Virtual Asset Guidance referred to on gmc.bt/GFSO.
• Banking the Crypto Business: Opening and Keeping Accounts for a GMC Digital Asset Firm — the bank account precondition to a licence in the GFSO application process, source-of-funds files and AML programme design.

Licence types

• Licensing a Centralised Crypto Exchange in GMC: The MTF/OTF Route Under Schedule 1 Paragraph 54 — operating an MTF for virtual assets (para. 54(1)(a)), the dealing, custody and money services activities a real exchange needs alongside it, and the order-routing exclusion for a facility where orders "are merely transmitted but do not interact" (para. 55).
• Stablecoin Issuance in GMC: The Fiat-Referenced Token Licence Under Schedule 1 Paragraph 53B — what the activity captures, how it sits beside providing money services (para. 52) and the connected-services exclusion (para. 53), and the Accepted Fiat-Referenced Token concept in s. 5A(1)(b)(ii).
• Crypto Custody in GMC: Providing and Arranging Custody of Virtual Assets Under Paragraphs 43 to 47 — safeguarding and administering virtual assets (para. 43), arranging custody (para. 46), systems and controls under GEN Chapter 3, and the exclusion for activities not constituting administration (para. 44).

Token classification

• Tokenisation and Digital Securities in GMC: When a Token Is a Specified Investment — shares (para. 87), debt instruments (para. 88), fund units (para. 93), options, futures and CFDs (paras. 94–96), rights and interests (para. 98) and structured products (para. 99A).
• Carbon Credits and Environmental Instruments as Regulated Investments in GMC: Paragraph 99B — an Environmental Instrument recognised by GFSO includes one that "attests to the reduction or removal of greenhouse gases" (para. 99B(b)); the link to GMC's Green Energy and Technologies pillar.

Perimeter questions

• DeFi, DAOs and Non-Custodial Protocols in GMC: Where the Regulatory Perimeter Actually Falls — the "by way of business" test (Schedule 1, Part 1, para. 3), the non-GMC person exclusions (paras. 71, 79) and how they apply to decentralised architecture.
• Crypto SaaS, Trading Infrastructure and Market Data Vendors in GMC: When Software Is Not a Regulated Activity — arrangements not causing a deal (para. 17), enabling parties to communicate (para. 18), order routing (para. 55), sale of goods or supply of services (para. 76) and incidental information (para. 81).
• Crypto Mining, Digital Asset Treasuries and Green Energy in GMC — when mining and staking need a licence, long-term energy and lease structuring through the GMC one-stop shop, and appropriation of trading stock for capital purposes (Income Tax Act 2025, s. 10J).

Frequently asked questions

Is there a separate "VASP licence" in GMC?

No. Virtual asset businesses are licensed under the same Financial Services Act 2025 framework as other financial firms, activity by activity, with the Virtual Asset Guidance as an overlay. The licence names the Schedule 1 activities the firm may conduct.

Which activities does a spot exchange typically need?

Operating an MTF (para. 54) is the core. Depending on the model, dealing as principal or agent (paras. 4, 12), providing custody (para. 43) and providing money services (para. 52) may also be needed. Each is assessed separately by GFSO.

Can any token be listed on a GMC exchange?

GFSO may prescribe the requirements and factors for a virtual asset to be an Accepted Virtual Asset (s. 5A(1)(b)(i)). Listing decisions therefore turn on GFSO's rules and directions, not on the operator alone.

Does a foreign exchange serving GMC users need a licence?

The question is whether it carries on a Regulated Activity by way of business in GMC (s. 16) and whether a non-GMC person exclusion applies (paras. 71, 79). The financial promotion rule also catches communications from outside GMC that are "capable of having an effect in GMC" (s. 18(3)).

How are crypto gains taxed?

Companies pay 15% on chargeable income (Income Tax Act 2025, s. 43(1)(a)). Non-citizen individuals pay 0% on chargeable income derived on or before 31 December 2030 (s. 43(1)(ba)). Whether a specific gain is income depends on the ordinary rules.

You may contact Basnet Law at basnet@basnetgmc.com or office@basnetgmc.com for any legal queries related to GMC.

References

• Financial Services Act 2025, ss. 5A, 5B, 16, 18(3); Schedule 1, Part 1 para. 3, Part 2 paras. 4, 12, 17, 18, 43, 44, 46, 52, 53, 54, 55, 71, 76, 79, 81, Part 3 paras. 87, 88, 93, 94–96, 98, 99A, 99B
• Income Tax Act 2025, ss. 10J, 43(1)(a), 43(1)(ba)
• GEN Rulebook 2026, Ch. 3, 4.5, 5.5