Crypto Exchange Licence in GMC: Legal Advisory

GMC does not have a separate crypto licence, and that is the point: virtual assets sit inside the same primary legislation as every other financial instrument, so an exchange is licensed for exactly the activities its model involves, no more and no fewer.

Define the permission stack: Operating a Multilateral Trading Facility plus, as the model requires, Dealing in Investments as Principal, Dealing as Agent, Providing Custody and Providing Money Services.

Test the perimeter: whether an order-routing model falls outside MTF operation under the order-routing exclusion, and whether non-GMC activity is excluded.

Advise on the token listing framework for Accepted Virtual Assets under the Act and the Virtual Asset Guidance.

Draft market rules, surveillance and conflicts arrangements against the Market Infrastructure Rulebook and the General Rulebook.

Advise on structuring client asset segregation, hot and cold wallet policy and settlement finality for GFSO review.

Advise on the Approved Person applications for the Senior Executive Officer, Compliance Officer and MLRO.

Exchange operators seeking a regulated base with a named virtual asset perimeter on the face of primary legislation. Brokers and OTC desks whose matching engine may cross the line from order routing into operating a venue. Existing exchanges adding a GMC entity to serve international clients. Market infrastructure providers offering clearing or settlement for digital assets.