Service

Crypto License for a Custody Provider

Institutional custody is a high-value, high-fee segment with limited credible counterparties. Wyoming SPDI, ADGM, FINMA-regulated and Jersey-registered custodians are the live universe — each with materially different capital, technology and audit obligations.

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Quick Facts

Parameter	Value
Best fit clients	Institutional custodians serving funds, family offices, exchanges and corporates.
Best jurisdictions	Hong Kong (TCSP) · Switzerland (FINMA) · UAE (ADGM) · USA (Wyoming SPDI) · Jersey
License types involved	TCSP, FINMA, FSP custody, SPDI

Who is this for?

Institutional custodians serving funds, family offices, exchanges and corporates. The licensing requirement turns on activity scope and customer geography — see the jurisdictions and licence-stack notes below.

What licences does a custody provider need?

The licence stack depends on activity scope and customer geography. The starting set for this service vertical is: TCSP, FINMA, FSP custody, SPDI. Each component covers a distinct regulated activity — exchange, custody, payment, advisory, brokerage, issuance — and several models stack two or three together. Read the services hub for the full glossary and the regulation guides for the underlying frameworks.

Best jurisdictions for custody provider

The credible shortlist is below. Each card opens a full country page with the regulator, capital, timeline and process detail.

Jersey

Regulator: Jersey Financial Services Commission (JFSC)
Timeline: 12–20 weeks
Min. capital: Substance-based

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Switzerland

Regulator: FINMA + SROs (e.g. VQF)
Timeline: SRO 2–3 months · Fintech 6–9 months · Banking 12–18 months
Min. capital: Fintech: CHF 300,000 · Banking: CHF 10,000,000 · SRO: none

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Hong Kong

Regulator: SFC + HKMA + Companies Registry (TCSP)
Timeline: 12+ months (VATP)
Min. capital: VATP: HKD 5–10M paid-up + HKD 3M liquid

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Common pitfalls

Wrong jurisdiction first. Founders pick the cheapest or fastest, then discover banks won’t onboard them. Banking-friendly jurisdiction first, then optimise;
Underestimating substance. Resident directors and substantive offices are not optional. Paper presence fails first examination;
Treating banking as bolted-on. A licence without a working bank account is unusable. Banking strategy is part of jurisdiction selection;
Ignoring year-one supervision. External audit, AML refresh, MLRO continuity. Calendar from day one;
Single-jurisdiction thinking. Real operators run multi-jurisdictional structures. Plan two-to-three years out, not one engagement at a time.

How the engagement runs

Every licensing engagement runs the same eight stages from kickoff to authorisation. Named deliverables at each stage. The same project manager runs the file end-to-end.

01
Strategy and gap analysis

Map the business model to credible licence categories. Score capital, timeline, banking risk and post-licence supervision burden.
02
Jurisdiction selection

Compare two-to-three credible options on cost, speed, banking access and counterparty trust. Decision committed in writing.
03
Company formation and substance

Local entity, resident director, registered office, AML officer. All set up in parallel to compress the timeline.
04
Documents and compliance pack

Beneficial-ownership chain, source-of-funds file, CVs, fit-and-proper, business plan, three-year financials.
05
AML / KYC programme

Risk assessment, transaction-monitoring rules, sanctions screening, MLRO matrix, FATF Travel Rule integration.
06
Application submission

Application file built to the actual reading list of the regulator’s examiners — not a generic template. Covering memo addresses common RFI triggers.
07
Regulator engagement

Weekly status, RFI responses inside the published service-level windows, regulator-meeting prep and rehearsal.
08
Authorisation and onboarding

Banking, payment rails, audit-firm appointment, year-one supervision calendar locked in.

Pricing

Fixed-scope quote at engagement.

One number covers regulator fee, capital indication, legal fees, year-one substance (resident director, registered office, AML officer where required) and the first year of ongoing supervision. We do not bill licensing engagements on a partner-rate timesheet — the fee is committed upfront.

Lead experts

Specialists for this service.

Daniel R. Whitmore

Founder & Managing Partner

Jurisdictions: United Kingdom · United States · Jersey · Gibraltar · Switzerland

Languages: English, French

Layla A. Hassan

Partner — Head of MENA & APAC

Jurisdictions: United Arab Emirates · Singapore · Hong Kong · Australia

Languages: English, Arabic, Mandarin (working)

Marcus T. Andersson

Partner — Head of Americas & Offshore

Jurisdictions: Canada · El Salvador · Panama · BVI · Cayman Islands · Montenegro · Bosnia & Herzegovina

Languages: English, Swedish, Spanish

Frequently asked questions

Do I need a license for a custody provider?

In most jurisdictions yes. The threshold question turns on activity scope and customer geography. Institutional custody is a high-value, high-fee segment with limited credible counterparties. Wyoming SPDI, ADGM, FINMA-regulated and Jersey-registered custodians are the live universe — each with materially different capital, technology and audit obligations.

Which jurisdiction is best for a custody provider?

The credible shortlist is Hong Kong (TCSP), Switzerland (FINMA), UAE (ADGM). The right pick turns on customer geography, capital tolerance and banking strategy.

What licence types are involved?

For this service vertical, the typical licence stack is: TCSP, FINMA, FSP custody, SPDI. The exact combination depends on the operating model and target customer base.

How long does the licensing engagement take?

Engagement length depends on the chosen jurisdiction. Light-touch jurisdictions complete in 4–12 weeks. Tier-1 onshore jurisdictions take 6–14 months from kickoff to authorisation.

How much does it cost?

Total first-year cost depends on the jurisdiction. We provide a fixed-scope quote at engagement that covers regulator fee, capital indication, legal fees, substance and the first year of ongoing supervision.

What documents will I need?

Beneficial-ownership chain, source-of-funds documentation, director CVs, fit-and-proper questionnaires, business plan with three-year financials, AML/KYC programme manual and a technology architecture description. The exact set varies by jurisdiction and licence type.