Ask any digital asset firm what killed its last expansion and the answer is rarely the licence. It is the bank account. A regulator grants approval subject to conditions, one of which is a bank account, and banks will not open an account for a firm that is not yet licensed. In May 2026 the Gelephu Mindfulness City Special Administrative Region announced a fast-track pathway combining incorporation, financial services approval and corporate banking into one process, aimed at firms already licensed in Singapore, Abu Dhabi Global Market or Hong Kong. It is a serious answer to a real problem. It is also, as GMC itself has said plainly, not passporting.
In short
- The Gelephu Financial Services Office is the independent regulator of all financial services and virtual assets activities in GMC. One perimeter, one rulebook set, one supervisor.
- The published licensing path has seven steps, from an initial meeting with the regulator through an in-principle approval with preconditions to the issue of a financial services licence.
- In-principle approval is not a licence. It is conditional, and the conditions typically include incorporation, a bank account, capital, an office and staff.
- The fast-track announced in May 2026 gives accelerated review to firms already licensed in Singapore, Abu Dhabi Global Market or Hong Kong, and bundles incorporation, approval and banking. GMC has stated that firms must still comply with GMC's own regulatory standards and supervision process.
- The bundled banking is a corporate account with DK Bank across nine currencies: US dollar, pound sterling, euro, Australian dollar, Japanese yen, Singapore dollar, Indian rupee, Hong Kong dollar and Bhutanese ngultrum, with bitcoin-backed lending and fiat to crypto rails, and banking fees waived for six months and then discounted.
- The correction that matters: a foreign licence simplifies due diligence. It does not substitute for local review, local licensing conditions or ongoing local supervision.
One regulator, and why that is not a slogan
In most financial centres a firm that trades securities and also holds crypto deals with at least two authorities and frequently three, each with its own perimeter, its own application form and its own view of what the firm is. GMC has not built it that way. The Gelephu Financial Services Office is described by GMC as the independent regulator of all financial services and virtual assets activities in the city, and virtual asset firms are licensed under the same framework as everyone else, supplemented by virtual asset guidance.
The statutory architecture supports that claim. The Financial Services Act 2025 sets out the regulated activities in a single schedule. Dealing in investments as principal and as agent, arranging deals, advising on investments or credit, providing and arranging custody, managing assets, managing a collective investment fund, acting as its administrator or as trustee of an investment trust, accepting deposits, providing credit, providing money services, effecting and carrying out contracts of insurance and insurance intermediation all sit in one list. So do the two activities that define the digital side: issuing a fiat-referenced token, and operating a multilateral trading facility or organised trading facility. There is no separate crypto statute and no separate crypto regulator.
The rulebooks follow the same logic. GMC has adopted the financial services framework of an established international financial centre under the Application of Laws Act 2024 and is progressively enacting it as GMC law, the Financial Services Act 2025 being the first and largest instalment. The published rulebooks cover anti-money laundering and sanctions, conduct of business, funds, market infrastructure, prudential requirements for insurance, banking and investment firms, and the general rulebook governing systems, controls, approved persons and applications. A practitioner who knows that framework will recognise the furniture immediately, and that familiarity is itself the product.
The seven steps, as published
- Contact the office and hold an initial meeting. This is where the perimeter question is settled: which activities you will carry on, whether they are regulated, and which exclusions you rely on.
- Present the business model. Not a pitch deck. A description of the activities, the client types, the flows and the risks.
- Submit the application forms and pay the non-refundable fee.
- Regulator review, including possible interviews of personnel. The general rulebook requires an applicant to demonstrate adequate and appropriate resources including financial resources, that it is fit and proper, that it is capable of being effectively supervised, and that it has adequate compliance arrangements including policies and procedures. Fitness and propriety is assessed across the governing body, controllers, group connections, business model and anything that might harm the integrity or reputation of the regulator or of GMC.
- In-principle approval, with preconditions.
- Fulfil the conditions: incorporation, bank account, capital, office and staff.
- Issue of the financial services licence.
Two structural requirements sit behind step six. Where a licensed firm is a body corporate incorporated in GMC, the general rulebook requires its head office and registered office to be in GMC, and an applicant must satisfy the regulator it will meet that requirement when the licence is granted. The regulator judges head office location case by case, looking at where the directors, partners and senior management are and where day-to-day operational, control, management and administrative arrangements sit. A firm that does not satisfy the regulator on this point will not, on that ground alone, be considered fit and proper.
The second is mandatory appointments. A licensed firm must appoint, and keep appointed at all times, a Senior Executive Officer, a Compliance Officer and a Money Laundering Reporting Officer, with a Finance Officer required for banks and insurers, each held by approved persons. Those three must be resident in GMC or Bhutan, though the rulebook contemplates a waiver of residence for the compliance and money laundering roles, considering the firm's nature, scale and complexity and whether a remote officer can do the job.
In-principle approval is therefore the point at which a licensing project becomes a hiring, leasing and banking project. That is the structural reason the loop described at the top of this article exists.
The fast-track, and what it actually changes
In May 2026 GMC announced a fast-track licensing pathway. Firms already licensed in Singapore, Abu Dhabi Global Market or Hong Kong receive accelerated review, and the pathway combines incorporation, approval by the Gelephu Financial Services Office and corporate banking into one process. Jigdrel Singay, GMC board member and digital assets lead, framed it in terms of recognition rather than substitution: if a company has already demonstrated credibility in leading jurisdictions, GMC recognises that and enables it to move faster.
Take that at its word, because it is the accurate description. What the fast-track changes is the evidentiary burden at step four. A firm that has already satisfied a demanding regulator on fitness and propriety, on financial resources, on governance and on compliance arrangements arrives with a file that a reviewer can work through quickly. Diligence that would otherwise be done from scratch is instead verified.
What the fast-track does not change is everything else. GMC has stated expressly that firms must still comply with GMC's own regulatory standards and supervision process. There is no passport. A licence granted elsewhere does not authorise a regulated activity in or from GMC. The GMC licence is a GMC instrument, granted on GMC criteria, carrying GMC conditions, and supervised in GMC afterwards. The head office requirement, the mandatory appointments, the prudential rulebook, the conduct rules, the anti-money laundering regime, the reporting obligations and the regulator's information gathering powers all apply on the same terms to a fast-tracked firm as to any other.
Nor does prior licensing carry across to a different activity. A firm licensed abroad for custody that wants to operate a trading facility in GMC is applying for something its home regulator has not assessed. The recognition runs to credibility, not to scope.
The in-principle approval given to BTSE Bhutan in May 2026, for operating a multilateral trading facility for virtual assets and for providing institutional-grade custody, illustrates both the pace and the limits. It was reported as the first exchange approval in GMC, and it remained conditional on satisfying pre-conditions before the firm could begin operating.
The banking piece
The bundled offering is a corporate account with DK Bank, reported as Bhutan's first licensed digital bank, supporting nine currencies: US dollar, pound sterling, euro, Australian dollar, Japanese yen, Singapore dollar, Indian rupee, Hong Kong dollar and Bhutanese ngultrum. It includes bitcoin-backed lending and fiat to crypto rails, with banking fees waived for the first six months and discounted thereafter.
Three observations for anyone modelling this.
First, the currency list is the interesting part, not the fee holiday. A firm that can hold US dollars, Singapore dollars, Hong Kong dollars and Indian rupees in one institution alongside crypto rails has solved a treasury problem, not just an onboarding problem. GMC's currency law reinforces this: every dollar reference in the GMC Acts is read as United States dollars, so capital requirements, fines, share capital and tax computations are all in one currency.
Second, DK Bank is already embedded in the jurisdiction's digital asset infrastructure. When the gold-backed token TER launched on Solana in December 2025 under a GMC sovereign framework, custody sat with DK Bank.
Third, an account offered as part of a pathway is still subject to the bank's own onboarding, anti-money laundering and risk appetite. The pathway coordinates the parties. It does not remove the bank's judgement, and no law compels a bank to accept a customer.
What this does not solve yet
The fee for an application is described as non-refundable but is not published in the Acts, and neither are minimum capital requirements by licence category, which sit in the prudential rulebook and with the regulator. Processing times are not stated anywhere in legislation, including for the fast-track. Anyone quoting you a number of weeks is quoting an expectation.
The fast-track is a policy announcement rather than a provision of the Financial Services Act 2025. It does not alter the statutory criteria for a licence, and it confers no entitlement. The recognition is of prior diligence, and the regulator retains its discretion to make any enquiries it considers appropriate and to impose conditions.
The banking terms are commercial terms offered by a bank, not statutory rights. The six month fee waiver and the subsequent discount are the bank's offer and can change.
And GMC is a young supervisory environment. The framework is recognisable because it is built on the model of an established international financial centre, but local supervisory practice, enforcement precedent and waiver decisions are still being written. Firms that need a deep archive of regulatory precedent should price that. Firms that value direct access to a regulator will find the trade worth making.
Frequently asked questions
Does my Singapore, ADGM or Hong Kong licence let me operate in GMC?
No. The fast-track gives accelerated review because your prior diligence is recognised, but GMC has stated expressly that firms must still comply with its own regulatory standards and supervision process. You need a GMC financial services licence for a regulated activity carried on in or from GMC.
What is an in-principle approval?
It is the stage of the published process at which the regulator indicates it is prepared to license you subject to preconditions. Those conditions typically include incorporation, a bank account, capital, an office and staff. You cannot carry on the regulated activity until the licence itself is issued.
Does one regulator really cover both crypto and traditional finance?
Yes. The Gelephu Financial Services Office is described as the independent regulator of all financial services and virtual assets activities in GMC, and both sit in the same schedule of regulated activities under the Financial Services Act 2025, with virtual asset firms licensed under the same framework plus virtual asset guidance.
Do I need people on the ground in Gelephu?
In substance, yes. A GMC-incorporated licensed firm must have its head office and registered office in GMC, and the Senior Executive Officer, Compliance Officer and Money Laundering Reporting Officer must be resident in GMC or Bhutan, subject to a possible waiver of residence for the compliance and money laundering roles.
How much does a licence cost?
The application fee is non-refundable but is not set out in the Acts, and minimum capital depends on the licence category under the prudential rulebook. These are figures to confirm with the regulator rather than to take from published summaries.
The bottom line
The GFSO model is the strongest institutional argument GMC has: one regulator, one perimeter covering finance and virtual assets together, built on a framework that international counsel already knows, with a pathway that deliberately attacks the licence-and-banking deadlock that stalls firms elsewhere. The fast-track is real and it is useful. It is also exactly what GMC says it is, which is accelerated review and recognition of prior diligence, not passporting, and any adviser telling you otherwise has not read the announcement. Come with a licensed track record and you will be reviewed faster. Come expecting to skip the review, the local appointments, the head office or the supervision, and you will be disappointed. Basnet Law Pte. Ltd. is on the ground in Gelephu and advises international clients through this process.
This article is general information about the law of the Gelephu Mindfulness City Special Administrative Region as at the date above. It is not legal advice and does not create a lawyer-client relationship.
You may contact Basnet Law at basnet@basnetgmc.com or office@basnetgmc.com for any legal queries related to GMC.
Sources
- Financial Services Act 2025 (Law No. 5 of 2025): s.17 (acting without a licence); s.27 (application for a Financial Services Licence); s.30 and s.31 (granting a licence); s.32 (variation); Schedule 1 Part 2 regulated activities including paragraphs 4, 12, 16, 28, 38, 43, 46, 48, 52, 53B, 54, 56, 59, 60, 61; Schedule 1 Part 3 specified investments.
- GEN Rulebook 2026 (Version 1.0): Rules 4.5 (location of offices); 5.2.6 to 5.2.12 (application and assessment criteria); 5.5.1 and 5.5.2 (mandatory appointments and residence); Chapter 8 (waivers, notifications and changes of control).
- Application of Laws Act 2024 (Law No. 1 of 2024): s.5 and Schedule B.
- Income Tax Act 2025 (Law No. 6 of 2025): s.62A (US dollar).
