Gibraltar Corporate & Compliance Services for Crypto & DLT Businesses

Resilience Group supports DLT-licensed businesses and crypto-native companies with company administration, regulatory compliance and fund administration in Gibraltar. We help firms establish the operational substance required by the GFSC, manage their AML/CTF obligations and administer crypto-focused fund structures — providing the infrastructure that allows founders to build their business rather than their back office.

Why Crypto & DLT Businesses Choose Gibraltar

The DLT Regulatory Framework

Gibraltar introduced a dedicated DLT framework in 2018. The 2017 regulations were replaced by the Financial Services (Distributed Ledger Technology Providers) Regulations 2020, which govern relevant use of DLT to store or transmit value belonging to others. Licensing depends on the actual activities, including custody and exchange models.

Ten Regulatory Principles, Practical Supervision

The current framework has ten regulatory principles, including fitness and propriety, fair customer treatment, adequate resources, governance, risk controls, financial-crime safeguards, systems resilience and market integrity. Firms should assess the current regulations and GFSC guidance for the full requirements.

MiCA Positioning

Gibraltar is outside the EU and not itself subject to MiCA as EU law. A Gibraltar business serving EU markets must separately assess applicable EU and member-state requirements.

Tax Treatment

Gibraltar's tax treatment depends on the nature and source of the income and the current tax rules; digital-asset businesses should obtain specific tax advice rather than assume that a revenue category falls outside Gibraltar tax.

What We Do for Crypto & DLT Businesses

Company Administration & Substance

The GFSC requires DLT firms to have genuine operational substance in Gibraltar — management and control must demonstrably reside in the jurisdiction. Resilience Group provides company administration services including registered office, company secretary, GFSC-approved directors and board governance support, enabling DLT businesses to meet the substance requirements without building a full local team from day one.

GFSC Licence Support

We assist with the preparation and submission of DLT provider licence applications, including business plan preparation, policy and procedure documentation, and pre-application liaison with the GFSC. Post-licence, we manage the ongoing regulatory reporting, notification obligations and governance requirements that the DLT regulations impose on licensed firms.

AML/CTF Compliance

DLT firms are Relevant Financial Businesses under Gibraltar's AML/CTF framework and must implement and maintain robust customer due diligence, transaction monitoring and suspicious transaction reporting systems. We provide MLRO services, AML/CTF policy frameworks and ongoing compliance oversight tailored to the specific risks of the crypto sector, including blockchain analytics integration and high-risk customer protocols.

Crypto Fund Administration

For investment managers running crypto-focused funds — whether liquid token funds, venture-style digital asset funds or hybrid structures — Gibraltar's EIF and Private Fund regimes offer a regulated or flexible vehicle respectively. As a licensed fund administrator, we provide NAV calculation, investor administration, AML/CTF compliance and GFSC reporting for crypto funds, with the technical capability to handle non-standard asset classes.

Gibraltar's DLT Regulatory Framework

DLT providers carrying on regulated activities are supervised by the GFSC under the Financial Services (Distributed Ledger Technology Providers) Regulations 2020. The ten regulatory principles, including market integrity, apply alongside ongoing supervisory and financial-crime requirements.

The licensing path and any phased testing depend on the GFSC's assessment of the proposed business. Obtain a current scope assessment before launching custody, exchange or other DLT value-transfer services.

Relevant businesses must also assess the Proceeds of Crime Act 2015 and applicable GFSC AML/CFT/CPF guidance. Resilience's compliance team supports operational controls; legal advice is provided separately.

Frequently asked questions

• Does every crypto company in Gibraltar need a DLT licence?

  The DLT licence applies to firms that use distributed ledger technology to store or transmit value belonging to others — primarily exchanges, custody providers and DLT-based payment systems. Companies that merely hold or invest in crypto assets on their own account, or that provide technology services without handling client assets, may not require a DLT licence, but should seek regulatory guidance from the GFSC before commencing operations.

• How long does a GFSC DLT licence application take?

  The GFSC does not publish a fixed timeline, and the process depends heavily on the completeness of the application and the complexity of the business model. Pre-application engagement with the GFSC is strongly recommended and typically reduces the overall timeline. Firms should budget for a minimum of several months from initial submission to licence grant.

• Is Gibraltar subject to MiCA?

  No. Gibraltar is a British Overseas Territory and not a member of the European Union, so MiCA does not apply. However, firms that have EU-based customers or that passport services into EU member states may still have MiCA exposure depending on the specific activity and distribution model. Gibraltar-based DLT firms should take specialist legal advice on their EU nexus.

• What corporate governance does a DLT firm need in Gibraltar?

  The GFSC requires DLT firms to have effective corporate governance mechanisms, including appropriate board composition, the four-eyes principle (separation of functions, dual control) and documented management procedures. The firm must have at least two senior individuals who are fit and proper and approved by the GFSC, and must demonstrate that management and control is genuinely exercised in Gibraltar.

• Can Resilience Group act as a GFSC-approved director for a DLT company?

  Yes. Resilience Group provides corporate director services, including GFSC-approved director appointments, for DLT-licensed entities. Our directors participate actively in governance and maintain the substance and management and control requirements expected by the GFSC.

• Can a Gibraltar DLT firm administer a crypto fund?

  The DLT licence and the fund administration licence are separate authorisations. A DLT firm that also wants to administer a Gibraltar fund needs to hold or appoint a separate GFSC-licensed fund administrator. Resilience Group holds the fund administration licence and can be appointed as administrator by crypto businesses establishing Gibraltar fund vehicles.