The Gelephu Mindfulness City Special Administrative Region (GMC) does not issue a separate "VASP licence". Virtual asset businesses are licensed by the Gelephu Financial Services Office (GFSO) under the same Schedule 1 Regulated Activities as traditional finance, with GFSO's Virtual Asset Guidance applied in addition. The practical job is translating what a VASP actually does into the activities the Act recognises, then applying for one licence that covers all of them. Basnet Law Pte. Ltd. is the first law firm incorporated in GMC. We map your VASP services to the correct activities under the Financial Services Act 2025 and manage the licence application with GFSO. This page shows how that mapping works and what the application involves.
How we help
- Translate a VASP business description into the Regulated Activities.
- Identify exclusions that may remove an activity from the perimeter, including order routing, non-GMC persons and group arrangements.
- Prepare the application for a single Financial Services Licence covering every activity the model needs.
- Build the Virtual Asset Guidance overlay into policies: token acceptance, wallet controls, travel-rule style transfers and AML.
- Draft the Accepted Virtual Asset assessment for each token to be supported.
- File Approved Person applications under the GEN Rulebook and later scope changes as products are added.
How GMC virtual asset licensing works, in plain terms
The Financial Services Act 2025 prohibits carrying on a Regulated Activity by way of business in GMC without being a Licensed Firm or an Exempt Firm. A Regulated Activity is any activity of the Act. The Schedule writes Virtual Assets into the activity definitions themselves rather than into a separate chapter. GFSO confirms that the regulated activities apply to virtual assets such as spot cryptocurrencies, and that firms carrying on virtual asset activities must also comply with its Virtual Asset Guidance.
The common VASP service lines map as follows:
| VASP service | Schedule 1 activity |
|---|
| Exchange between virtual assets and fiat, or between virtual assets, as principal | Dealing in Investments as Principal |
| Executing client orders as agent | Dealing in Investments as Agent |
| Introducing or arranging trades for others | Arranging Deals in Investments |
| Operating a matching venue | Operating a Multilateral Trading Facility |
| Safekeeping or administering client virtual assets | Providing Custody; Arranging Custody |
| Fiat on- and off-ramps, remittance, payment accounts | Providing Money Services |
| Issuing a single-currency stablecoin | Issuing a Fiat-Referenced Token |
| Discretionary portfolio management of virtual assets | Managing Assets |
| Advising on buying or selling virtual assets | Advising on Investments or Credit |
| Running a token fund | Managing a Collective Investment Fund |
The Act lets GFSO prescribe requirements for Licensed Firms dealing in Virtual Assets and set the criteria for an Accepted Virtual Asset. It prohibits any Regulated Activity involving privacy tokens, algorithmic stablecoins or similar technology, and it prohibits misleading, deceptive, fraudulent or dishonest conduct in relation to a Virtual Asset or a Fiat-Referenced Token. Capital, fees and the content of the Virtual Asset Guidance are set by GFSO, and we confirm the current requirements at engagement.
Who this is for
- Exchanges, brokers and OTC desks moving to or expanding into GMC.
- Custodians, wallet providers and staking operators.
- Payment and remittance firms handling virtual assets.
- Token issuers and fund managers in the digital asset sector.
How an engagement runs
- Activity mapping and the exclusions, documented in a perimeter memorandum you can rely on.
- Token and product inventory, with an Accepted Virtual Asset analysis for each token.
- Regulatory business plan, policies and governance meeting the GEN Rulebook 2026 and the Virtual Asset Guidance.
- GFSO initial meeting, application, interviews and In-Principle Approval.
- Incorporation, capital, bank account, premises and staff, then licence issue.
Frequently asked questions
Is "VASP" a legal term in GMC?
No. GMC law does not create a VASP category. The services usually described as VASP activities are each Regulated Activities, and a firm applies for a Financial Services Licence listing the ones it will carry on. We draw up that list with you.
Do I need one licence or several?
One. The Act allows GFSO to grant a single licence covering several Regulated Activities, and a Licensed Firm applies to vary its licence rather than seek a new one when it adds activities later.
Which tokens can a licensed VASP support?
Only those that meet GFSO's requirements for an Accepted Virtual Asset. Privacy tokens and algorithmic stablecoins are prohibited by the Act. We assess each token before you list it.
Does a non-custodial software provider need a licence?
Possibly not. The "by way of business" test, the order-routing exclusion and the incidental information exclusion can take pure software outside the perimeter. This is fact-specific, and we set the analysis out in writing.
What about serving GMC clients from abroad?
The Act excludes certain Non-GMC Persons dealing with or through Licensed Firms or responding to legitimate approaches. Marketing into GMC engages the financial promotion rules, which we review before anything is published.
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.
