Gelephu Financial Services Office (GFSO)

The Gelephu Financial Services Office (GFSO) is the independent regulator of all financial services (across traditional finance and blockchain/digital assets) in GMC, and also has the mandate of developing the financial services and blockchain ecosystem in GMC.

Overview of the Regulatory Framework

In Phase One of the development of GMC's regulatory framework for financial services and digital assets, GFSO draws on Abu Dhabi Global Market (ADGM) laws as articulated in GMC's "Application of Laws Act 2024". This allows GMC to immediately draw on global best practices based on English Common Law. In the current Phase Two, GFSO is progressively issuing its own laws that will apply to all regulated financial services and digital asset activities in GMC.

Financial Services Act 2025

The legislation governing financial services and virtual assets in GMC is the single omnibus Financial Services Act 2025 ("FSA"), and its subsidiary legislation termed "Rulebooks".

Within the FSA, refer to "Schedule 1 Regulated Activities" from page 252 onwards for the list and definition of regulated activities in GMC. Any firm wanting to carry out one or more of these regulated financial activities must obtain a Financial Services Licence from the GFSO.

The regulated activities can be carried out with respect to either traditional assets (e.g. securities) or virtual assets (e.g. spot cryptocurrencies).

Subsidiary Legislation: Rulebooks

The subsidiary legislation under FSA which apply in GMC are listed below. Firms licensed by the GFSO must comply with both FSA and these Rulebooks (as applicable):

1. Anti-Money Laundering and Sanctions Rulebook (AML)
2. Captive Insurance Business Rulebook (CIB)
3. Conduct of Business Rulebook (COBS)
4. Fund Rulebook (FUNDS)
5. General Rulebook (GEN)
6. Glossary Rulebook (GLO)
7. Market Infrastructure Rulebook (MIR)
8. Market Rules (MKT)
9. Prudential — Insurance Business (PIN)
10. Prudential — Investment, Insurance Intermediation and Banking Rules (PRU)

For firms engaged in virtual asset (i.e. crypto) activities, they will also need to comply with additional Virtual Asset Guidance.

What is the Licensing Process in GMC?

1. First contact the GFSO at gfso@gmc.bt to arrange an initial meeting.
2. At the initial meeting, you will need to present your proposed business model and explain why you wish to set up in GMC. Subject to the outcome of this initial meeting, the GFSO may invite you to submit an application for a Financial Services Licence and send you the application form(s).
3. When you submit your application form(s), the GFSO will issue the invoice for the non-refundable application fee you are required to pay.
4. The GFSO will review your application and request meetings with you where required. This may include interviewing key personnel from your business.
5. If your application is successful, you will receive an In-Principle Approval ("IPA") containing a number of pre-conditions you must satisfy before you are issued the actual Financial Services Licence. Note that the IPA does not permit you to conduct your business in GMC yet.
6. You must fulfill the IPA conditions, which will include incorporating a company in GMC via the Gelephu Corporate Registration Office ("GCRO") department within the GMCA, opening a bank account in GMC, injecting the required regulatory capital, obtaining office space in GMC, hiring key personnel, etc.
7. Once you have fulfilled all IPA conditions, the GFSO will issue the Financial Services Licence to you, which allows you to commence your business in GMC.

Application Checklist

• Application Form(s) for a Financial Services Licence. This includes submitting a general application form applicable to all applicants, and supplementary application forms for certain regulated activities pertaining to banking, broker-dealer, asset management and insurance activities.
• Business plan in GMC that illustrates its compliance with the relevant regulations
• Compliance Manual that describes the GFSO regulatory requirements the firm is subject to and its internal controls
• Anti-Money Laundering Manual that describes internal controls and measures undertaken against money laundering, terrorist financing, proliferation financing, financing of unlawful organisations and sanctions non-compliance, and the observance of and compliance with applicable sanctions.
• Shareholding structure, including all controlling interests
• Organisational chart of the applicant
• Curriculum vitae (CV) of the proposed Chief Executive Officer (CEO), Compliance Officer, Money Laundering Reporting Officer (MLRO) and other key individuals in the firm as applicable
• Transaction flow diagrams to describe the beginning to end of a typical transaction with regard to the proposed products and services to be offered in GMC
• Any other materials that GFSO requires from the applicant

Frequently Asked Questions

General

Licensing Process & General Requirements

Contact Us

For any enquiries, please contact us at: gfso@gmc.bt