The GMC Accelerated Licensing Pathway for Globally Licensed Firms: Eligibility, Process and Banking

A financial services or digital asset firm already licensed in Singapore, the Abu Dhabi Global Market or Hong Kong can apply to the Gelephu Mindfulness City on an accelerated review, and the Authority states that the firm receives a DK Bank corporate account as part of the same process. The pathway, announced by the Gelephu Mindfulness City Authority on 7 May 2026, treats incorporation, regulatory approval, bank account opening and the start of operations as one coordinated sequence. It does not replace a GMC licence: the firm still incorporates in GMC, satisfies its in-principle approval conditions and holds a Financial Services Licence for its regulated activities. Only investment managers from a Recognised Foreign Jurisdiction operate without a GMC licence, managing GMC domestic funds on a four-week no-objection.

In short

  • Firms licensed in established financial centres, named by the Authority as Singapore, the Abu Dhabi Global Market and Hong Kong, are eligible for accelerated review of a GMC licence application.
  • Investment managers licensed in a Recognised Foreign Jurisdiction, initially Singapore, Japan, ADGM, DIFC, Hong Kong and India, manage a GMC domestic fund on a four-week no-objection from the Gelephu Financial Services Office (GFSO) without a GMC licence.
  • The process is one coordinated sequence: incorporate, receive regulatory approval, open the bank account, begin operations. The Authority states that licensed companies are provided with a DK Bank corporate account as part of it.
  • Accelerated review shortens the assessment. It does not remove the GMC licence, the in-principle approval conditions or GFSO supervision. A foreign licence is evidence of standing, not a passport.
  • DK Bank, as described by the Authority and the bank, offers nine currencies, BTC-backed lending and asset swaps, fiat and digital asset on- and off-ramps, and fees waived for at least six months.
  • Ceffu and BIT, formerly Matrixport, are the firms the Authority quotes as having used it.

What the pathway is

The accelerated licensing pathway is a review track within the ordinary GFSO licensing process. A firm already regulated in a financial centre the Authority recognises applies for its GMC Financial Services Licence in the usual way, and GFSO assesses the application on an expedited basis because a comparable regulator has already examined the firm. The Authority describes the result as moving from application to full operational readiness in a significantly shorter timeframe, by combining expedited review with immediate access to banking. Elsewhere the bank account is a separate and later negotiation with a bank that has no obligation to say yes, which the Authority says can add months of delay after approval. In GMC the account is built into the process through DK Bank.

Who is eligible

The Authority names Singapore, the Abu Dhabi Global Market and Hong Kong as examples of established financial centres, so the list illustrates the standard applied rather than closing it. What GFSO is looking for is a current licence from a regulator whose standards it regards as comparable. Eligibility is about the applicant, not the activity: a custodian, an exchange, a broker, a lender or an asset manager can each use the pathway, and the GMC licence covers the activities the firm will actually carry on under Schedule 1 of the Financial Services Act 2025.

The fund-manager version: Recognised Foreign Jurisdictions

For investment managers, the same idea has a more developed form in the GFSO guidelines for funds and investment managers, in force from 1 October 2026. A manager licensed or regulated by the competent authority of a Recognised Foreign Jurisdiction may manage assets for a GMC domestic fund without a separate GMC fund management licence. A Recognised Foreign Jurisdiction is one GFSO has designated by notice on its website; the initial list is Singapore, Japan, ADGM, DIFC, Hong Kong and India. The manager must satisfy three conditions:

  • A valid and subsisting licence. A fund management licence, or equivalent authorisation, from the competent authority of the Recognised Foreign Jurisdiction.
  • A clean three-year record. No material regulatory action, sanction or disciplinary proceeding in the home jurisdiction within the preceding three years.
  • AML, CFT and sanctions compliance. Compliance with the anti-money laundering, countering the financing of terrorism and sanctions requirements that GFSO prescribes.

The manager seeks a no-objection from GFSO at least four weeks before it starts managing assets in GMC, and GFSO targets its no-objection within four weeks of the submission. A launch no-objection for an exempt fund or a qualified investor fund runs on the same timetable, so the two requests are usually filed together.

Why the Authority created it

The Authority gives three reasons. First, existing regulatory standing: a firm that has satisfied a comparable regulator has already been tested on the matters GFSO cares about, and the Authority's Digital Assets and Fintech Lead, Jigdrel Singay, describes the pathway as recognising that and letting such firms move faster. Second, less duplication: the review builds on the home regulator's work rather than repeating it. Third, standards are maintained. DK Bank's Chief Executive Officer, Yu Dong Zheng, adds the commercial logic: in most financial centres getting licensed is only half the battle, and getting a bank account is where companies get stuck.

One coordinated process: incorporate, approve, bank, operate

The Authority describes four steps carried out as a single, coordinated process:

  • Incorporate. The firm forms its GMC entity through the Gelephu Corporate Registration Office (GCRO).
  • Receive regulatory approval. GFSO reviews the application on the accelerated track and issues in-principle approval, then the licence once the conditions are met.
  • Open a bank account. The DK Bank account is provided as part of the process rather than negotiated afterwards.
  • Begin operations. With the licence and the account in place, the firm trades.

In practice the steps overlap: incorporation and the bank account are conditions of in-principle approval, so the licensing file, the GCRO filing and the DK Bank onboarding run in parallel.

What accelerated review changes, and what it does not

Accelerated review changes the duration of GFSO's assessment, not the legal result. A firm on the pathway:

  • Still incorporates in GMC. The licence is issued to a GMC entity, not to the foreign parent.
  • Still receives a conditional in-principle approval. GFSO's guidance is that in-principle approval does not allow an applicant to conduct regulated activities until it has incorporated in GMC, opened a GMC bank account and met any other requirements that apply.
  • Still holds a GMC Financial Services Licence and is supervised by GFSO on the same terms as any other licensee.
  • Still appoints its approved persons in GMC, each meeting the fit and proper standard.

The foreign licence is evidence of standing and a reason to shorten the review. It is not a passport, and it authorises nothing in GMC by itself. The one exception is the fund-manager route: a manager from a Recognised Foreign Jurisdiction that meets the three conditions operates on a no-objection instead of a licence, and that exemption is confined to managing a GMC domestic fund. A firm from the same jurisdiction that wants to run an exchange, provide custody or deal in investments in GMC is on the licence track, accelerated or otherwise.

The banking component

The Authority states that companies which incorporate and receive a licence in GMC are provided with a corporate bank account through DK Bank as part of the process, so they can begin operations without delay. This is a commitment by the Authority and DK Bank rather than a provision of statute, and the account is opened through the bank's own know-your-customer process, run alongside the licence application rather than after it.

The Authority and DK Bank describe the account as designed for globally active financial and digital asset companies, with:

  • Nine currencies. Multi-currency accounts in USD, GBP, EUR, AUD, JPY, SGD, INR, HKD and BTN, the Bhutanese Ngultrum.
  • Digital asset financial services. BTC-backed lending and asset swap capabilities for liquidity management.
  • On- and off-ramps. Integrated rails for compliant movement between fiat and digital assets.
  • Preferential fees. Banking fees fully waived for at least the first six months for GMC companies, with discounted pricing thereafter.

The wider framework the Authority points to

The Authority places the pathway within a tax and regulatory framework it describes as designed to support real business activity, capital formation and long-term investment:

  • Priority-sector incentives. Targeted incentives including a 0% corporate rate dependent on the level of investment. The general company rate under the Income Tax Act 2025 is 15%, and the reliefs below it are approval-based.
  • A territorial tax system.
  • No capital gains, dividend or inheritance tax.
  • Non-citizen individual exemption to 2030. Foreign talent tax exemptions through 2030.
  • A treaty network. Double taxation agreements in place and expanding, including with Singapore.
  • Variable capital companies. VCC structures, modelled on established international fund jurisdictions, with enhanced flexibility.
  • Dispute resolution. An International Dispute Resolution Centre to support cross-border investment and legal certainty.

Who has used it

Ian Loh, Chief Executive Officer of Ceffu, a custodian, describes the process as balancing innovation with responsibility, rigorous but equally collaborative. John Ge, Co-Founder and Chief Executive Officer of BIT, formerly Matrixport, says the accelerated review is both fast and pragmatic, with GFSO engaging constructively while upholding high standards, which materially reduces execution risk for firms entering a new market.

How the engagement runs

  1. Eligibility and scope. We confirm the home licence and its status, and map the regulated activities the firm will carry on in GMC against Schedule 1 of the Financial Services Act 2025. Where a manager from a Recognised Foreign Jurisdiction will only manage a domestic fund, we advise on the no-objection route instead.
  2. Application pack. We prepare the GFSO application on the accelerated track, drawing on the home-regulator file for the business plan, controls, projections and approved person material, so GFSO can rely on work already done.
  3. Incorporation and banking in parallel. We form the GMC entity through GCRO and open the DK Bank account alongside the licence application, keeping the bank's know-your-customer file consistent with the GFSO file.
  4. In-principle approval and conditions. We work through the conditions, typically capital, premises, staffing, approved person appointments and the bank account, and file the evidence.
  5. Licence and operation. On issue of the licence the firm begins operations and we set up the compliance calendar: GFSO reporting, approved persons and the AML programme.
  6. Fund managers on the no-objection route. We file the manager's no-objection and, where relevant, the fund launch no-objection together, at least four weeks before the intended start, and handle GFSO's questions in that window.

Frequently asked questions

Eligibility

Which home jurisdictions qualify for the accelerated review?

The Authority names Singapore, the Abu Dhabi Global Market and Hong Kong as examples of established financial centres. A firm regulated elsewhere should ask GFSO whether its home regulator is treated as comparable.

Is the accelerated pathway the same as the Recognised Foreign Jurisdiction route for fund managers?

No. The accelerated pathway is a faster review of a GMC licence application, and the firm ends up licensed. The Recognised Foreign Jurisdiction route lets a manager licensed in Singapore, Japan, ADGM, DIFC, Hong Kong or India manage a GMC domestic fund on a no-objection without any GMC licence.

What are the three conditions for a foreign-licensed fund manager?

A valid and subsisting fund management licence or equivalent authorisation from a Recognised Foreign Jurisdiction; no material regulatory action, sanction or disciplinary proceeding at home in the preceding three years; and compliance with the AML, CFT and sanctions requirements prescribed by GFSO.

Does a foreign licence let my firm operate in GMC without a GMC licence?

Only for a fund manager from a Recognised Foreign Jurisdiction managing a GMC domestic fund. Every other regulated activity requires a GMC Financial Services Licence; the foreign licence supports an accelerated review of that application.

Process

How long does the accelerated review take?

The Authority describes it as significantly shorter than the standard process and has not published a fixed period. For comparison, a standard investment manager licence application reaches in-principle approval in two to three months on average, and the no-objection route is targeted at four weeks.

Can my firm start trading on in-principle approval?

No. The applicant must first incorporate an entity in GMC, open a bank account in GMC and meet any other regulatory requirements that apply.

Which regulated activities will the GMC licence cover?

The activities the firm will actually carry on in GMC under Schedule 1 of the Financial Services Act 2025, which need not match the home licence.

Banking and tax

Is the DK Bank account automatic?

The Authority states that companies licensed in GMC are provided with a DK Bank corporate account as part of the process. That is a commitment by the Authority and DK Bank rather than a provision of statute, and the account is opened through the bank's own onboarding alongside the licence application.

Which currencies does the account support, and what does it cost?

Nine: USD, GBP, EUR, AUD, JPY, SGD, INR, HKD and BTN. The Authority and DK Bank describe fees fully waived for at least the first six months, with discounted pricing thereafter.

What tax framework does a firm on the pathway land in?

The same as every GMC company: a 15% company rate under the Income Tax Act 2025 with approval-based reliefs down to 0% for priority sectors, a territorial system, no capital gains, dividend or inheritance tax, the non-citizen individual exemption to 2030, and a treaty network that includes Singapore.

The bottom line

The accelerated pathway is a faster route to the same destination. A firm licensed in Singapore, ADGM or Hong Kong still incorporates in GMC, meets its in-principle approval conditions and holds a GMC Financial Services Licence, but GFSO's review builds on the home regulator's work and, according to the Authority, the DK Bank account is delivered as part of the process rather than pursued afterwards. Fund managers from the six Recognised Foreign Jurisdictions have the further option of a four-week no-objection with no GMC licence at all. For a firm used to a licence followed by months of bank refusals, that coordinated sequence is the substance of the announcement.

Sources

  • Gelephu Mindfulness City Authority, press release on the accelerated pathway for globally licensed firms, dated 7 May 2026, published 12 May 2026.
  • Gelephu Mindfulness City Authority, Guidelines on Regulatory Requirements and Tax Incentives for Funds and Investment Managers, released 20 September 2026, paragraphs 2.6 to 2.9.
  • Gelephu Mindfulness City Authority, Frequently Asked Questions: Family Offices, Funds and Investment Managers, 20 September 2026, questions 6 to 8.
  • Financial Services Act 2025, Schedule 1.
  • Income Tax Act 2025.

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

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