The Financial Services Act 2025 has no separate licence called a digital bank or an e-money institution. A bank in the Gelephu Mindfulness City is a firm licensed for Accepting Deposits, and an e-money issuer is a firm licensed for Providing Money Services, whatever the channel. Which activity a product falls into determines the prudential rulebook, the board composition and the client money regime. Basnet Law Pte.

Classifying every customer balance as a deposit, stored value or a payment account before the product is built.

Testing the deposit exclusions, from group treasury and wholesale debt issuance to money received by other licensed firms.

Preparing the banking application, including the supplementary forms GFSO requires for banking and the prudential framework.

Designing a governing body that meets the non-executive and independent director rules for banks, and appointing the Finance Officer and the other mandatory officers.

Structuring e-money and wallet models under Providing Money Services and its exclusions.

Running the In-Principle Approval conditions: bank account, capital, office and personnel.

International banks and neobanks establishing a GMC deposit-taking subsidiary. E-money issuers and wallet providers whose balances are held to make payments rather than to fund lending. Fintechs deciding whether a balance model needs a banking or a money services licence. Firms licensed in Singapore, Abu Dhabi Global Market or Hong Kong considering the fast-track pathway.