- ADGM — Regulatory Perimeter Check
Do You Need an ADGM Crypto Licence?
A practical decision framework to determine whether your crypto business falls within the ADGM regulatory perimeter — or can operate without a licence. Answer a few questions and get your indicative classification in under two minutes.
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Are you carrying out a Virtual Asset activity in or from ADGM?
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If YES → you may require a licence
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If NO → you may fall outside the regulatory perimeter
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But the answer depends on what exactly you are doing. Take the assessment below.
The ADGM Licensing Decision Tree
Click through the same nine-step framework our regulatory team applies in a first assessment. Your answers route you to an indicative outcome — licence required, may be required, or not required.
Important
The Substance Test
ADGM applies a strict principle when assessing whether your business sits inside the regulatory perimeter:
The Governing Principle
It does not matter what you call your business — it matters
what your business actually does.
Common Misconceptions
The Four Arguments That Don't Work
These are the most common positions founders take when they believe they sit outside the perimeter — and why each one fails the substance test.
✕ "We're just a platform"
✕ "We don't hold funds"
✕ "We're decentralised"
✕ "We're offshore"
What We Deliver
From Indicative Answer to Definitive Position
The decision tree gives you an indicative answer. Our regulatory team converts it into a definitive, defensible position — before you engage with the FSRA.
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Business Model Classification
We map what your business actually does — not what it's called — against the FSRA's regulated activities framework.
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Licensing Requirement Assessment
A definitive view on whether licensing is required, which activities apply, and what the perimeter position is.
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Structuring Strategy — FSRA vs DLT Foundation
Where the regulated activity sits, where the token sits, and how the two interact without triggering unnecessary licensing.
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Regulatory Risk Analysis
Financial promotion, arranging, custody, and cross-border exposure risks — identified and mitigated before they become findings.
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Pre-Licensing Advisory
If licensing is required, we take you from classification through structuring, application strategy, and FSRA engagement — end to end.
Still Unsure?
Crypto Regulation Is Highly Fact-Specific
Two businesses that look similar can have completely different licensing outcomes, different capital requirements, and different regulatory obligations.
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The difference between the outcomes is rarely the idea — it is the structure, the control points, and the flows. That is what our regulatory team assesses.
Speak to Our Regulatory Team
Get a Definitive Answer on Your Licensing Position
Take your indicative result from the decision tree and turn it into a definitive regulatory position. Book a strategy call and let us assess your activities, token structure, and cross-border exposure.