Global comparison of the strongest digital asset licenses in 2025

Cryptocurrencies and digital assets in general have undergone tumultuous developments over the past decade. From a marginal innovation, they have become part of the financial mainstream. Today's exchange-traded funds (ETFs) allow even large and established players such as BlackRock, Goldman Sach, and Morgan Stanley to invest in this asset class.

The strongest licenses globally are usually those issued in jurisdictions with high credibility and strict oversight and reputation in the field of financial regulation. These licenses are then valued mainly because they allow companies to more easily gain the trust of potential clients, banking partners and access to international markets and investors. 

According to available sources, countries such as the United Kingdom and Switzerland have long determined the global gold regulatory standard in the field of digital assets.

According to the latest report by the comparison service Coincub, El Salvador is becoming  the new leader, overtaking Switzerland and taking the lead in the global ranking of digital asset regulation for 2025. 

El Salvador has built a reputation as a global hub for digital assets and has a strong focus on both creating a safe regulatory environment and harmonizing its rules with international gold standards.

The countries mentioned above are recognized for their most predictable and consistent regulatory environment. They combine advanced licensing structures with integrated supervision, enabling sustainable innovation while maintaining a high level of regulatory requirements and rigorous enforcement.

The cumbersome EU is no longer left out either , where the MiCA (Markets in Crypto-Assets Regulation) regulation is gradually coming into force and it is the first EU-wide legal and regulatory framework of its kind, the aim of which is to unify the rules for all member states and enable the so-called "passporting" license – a company licensed in one EU country can operate in all others. 

Let's now take a closer look at the individual regulators and the licenses issued. 

Great Britain

Financial Conduct Authority (FCA)

In the UK, a company (exchange, exchange, wallet provider) cannot operate without a license - the so-called Cryptoasset Registration, which is issued by the FCA. This is a legal requirement under the Money Laundering Regulations (MLR 2017). The registration confirms that the firm has anti-money laundering and counter-terrorism financing systems.

Firms offering derivatives may also need a full FCA license to provide investment services. 

FCA requirements:

FCA wants detailed evidence that the company has strong AML/CTF processes (transaction monitoring, client verification – KYC, reporting of suspicious activity). It is not enough just "paper" directives, FCA expects real and functional systems. Firms must demonstrate that they can identify risky clients (e.g. from high-risk jurisdictions).

The FCA examines the so-called "fit and proper test" – whether the company's management has sufficient experience in finance, risk management and compliance. The licensing application process requires extensive manuals, policies, and risk management plans. The process can take 6-12 months (sometimes longer) and requires specialized lawyers and consultants. Approved firms must continuously report to the FCA, update AML/KYC processes, and undergo checks.

Examples of companies that are registered with the FCA under the Digital Assets Rules: 

payment service PayPal UK Limited, the Kraken exchange, or the latest addition, IG Group.

Switzerland

Regulator FINMA (Swiss Financial Market Supervisory Authority)

In Switzerland, companies in the industry are primarily subject to the Anti-Money Laundering Act (AMLA). Any firm that professionally processes or transfers digital assets (exchange, exchange, custody wallet, payment processor) must either have membership in  a Self-Regulatory Organization (SRO) approved by FINMA or a direct license from FINMA if it performs activities that require a banking or investment license.

AML registration via SRO is a basic entry requirement for most providers in Switzerland. The SRO supervises compliance with AML/CTF rules.

A finTech license ("banking license light") allows you to hold cryptocurrencies or fiat assets of clients up to CHF 100 million without a full banking license since 2019.

The DLT Trading Facility license has been a special license for exchanges and trading platforms using blockchain technology since 2021.

A full banking or securities dealer license is required if the company manages more than CHF 100 million or trades securities.

FINMA requirements: 

AML/CTF compliance – mandatory KYC processes, transaction monitoring, reporting of suspicious activities. Client and risk identification – checking client identity, sanction lists, and geographic risks. Fit and proper test – management and key employees must have proven experience in finance, compliance and risk management.

Internal documentation – detailed risk management plans, compliance manuals and operating guidelines are mandatory.

Length of the process – membership in an SRO usually takes several months; Obtaining a FinTech or DLT license usually takes 6-12 months, sometimes longer, and requires the involvement of legal and compliance experts, SRO or FINMA fees.

Entities must continuously report, update AML/KYC processes and be subject to audits and controls. FINMA emphasizes robust AML/KYC processes, expert guidance and documentation. The process is time-consuming and financially demanding, and licensed companies are subject to ongoing supervision.

Examples of companies that are registered with FINMA under the Digital Assets Rules:

Amina Bank AG – one of the first banks in the world focused purely on digital assets, the SIX Digital Exchange (SDX), or fintech company BX Digital AG, which was the first to obtain a DLT Trading Facility license in 2025.

San Salvador

Regulator: CNAD (Comisión Nacional de Activos Digitales)

In El Salvador, the regulator issues  a DASP (Digital Asset Service Provider) license under the Digital Asset Issuance Law (Ley de Emisión de Activos Digitales – LEAD) and the accompanying Digital Asset Service Providers Regulation (Reglamento de Proveedores de Servicios de Activos Digitales – RPSAD). The license then authorizes the entities holding it to act as a regulated provider of digital asset services, including brokerage services, trading, and digital asset custody solutions.

Requirements for DASP License Granting:

Under the DASP licensing framework, entities commit to a comprehensive set of regulatory obligations based on the following key pillars:

Licence applicants must meet demanding financial stability and capital requirements, which must be demonstrated by regularly providing financial statements and independent audit reports to the regulator.

Cybersecurity & Certification – An applicant for a DASP license must submit to the regulator independent penetration test results with internationally recognized certification (including ISO/IEC 27001 and SOC 2), thereby demonstrating that its technological solutions meet the highest international security standards. 

Furthermore, the applicants undertake that client assets will be safely separated from the company's assets, and for the maximum level of protection of client funds, each company with a DASP license must use the services of the so-called DASP license. Custodiana, which is a specialized institution that takes care of the safety, security, and insurance of digital assets that protects clients' funds against various risks such as theft of digital assets, hardware damage, and the like.  

Each entity with a DASP license must also have an organizational structure that ensures that the company operates according to the conditions set by the regulator. The approval process for this license typically exceeds 12 months. 

Examples of companies that are regulated by CNAD under the DASP license:

Tether – the issuer of the globally most widely used stablecoin USDT, a global exchange Binance, or the latest licensee of this license, the broker Finprime.

EU

Regulator: ESMA (European Securities and Markets Authority)

In the EU, the situation is the most complicated, because it is not a single institution that would supervise the market, but the powers of attorney are divided roughly as follows: 

ESMA has a major role in the supervision of large crypto service providers (CASPs). The EBA (European Banking Authority) is in charge of stablecoins and makes sure that they are properly backed and secure. 

National regulators (such as BaFin, AMF, CySEC etc.) then grant licenses and carry out practical supervision of companies in their territory. 

The newly introduced legal and regulatory framework MiCA (Markets in Crypto-Assets Regulation) is intended to provide some standardization, and it is the first EU-wide framework of its kind, which aims to unify the rules for all member states and enable the so-called "passporting" license – a company licensed in one EU country can operate in all others.

MiCA Requirements

MiCA as a regulatory framework ensures consumer protection, brings legal certainty and clear rules, and forces providers to meet specific technological and security standards (custody, cybersecurity, incident management, risk management).

As usual, applicants for a MiCA license must meet demanding financial stability and capital requirements, which must be demonstrated by regularly providing financial statements and independent audit reports to the regulator, as well as the obligation to separate client funds from corporate funds, the obligation of safe custody and the possibility of consumer compensation.

Furthermore, the basic categories such as digital assets, asset-referenced tokens (ARTs), e-money tokens (EMTs), service providers (CASPs) are clearly defined. This then results in clear governance and compliance obligations for companies to comply with the law.

MiCA also emphasizes technological security and robust operational infrastructure to prevent FTX-type collapses or exchange hacks. Therefore, providers must implement systems for the prevention and detection of attacks, undergo regular penetration tests and audits, establish Business continuity and disaster recovery plans.

Ensure secure storage of private keys, have clear policies for access and control over keys. Mandatory protection of clients' assets from loss or theft. Clearly separate client systems and internal company systems, introduce so-called incident reporting and report any security incidents to the regulator (e.g. hack, data leakage, service outage) and many other obligations. 

Examples of companies that are regulated by ESMA under the MiCA license in the EU:

Circle – the issuer of the first stablecoin under the MiCA license – USDC, the global exchange Coinbase, or the latest acquirer of this license, the broker Bitvavo.

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