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 World's First DLT Regulatory Framework

Gibraltar was the first jurisdiction globally to introduce a comprehensive regulatory framework specifically for distributed ledger technology businesses. The Financial Services (Distributed Ledger Technology Providers) Regulations 2017, which came into force on 1 January 2018, regulate firms that use DLT to store or transmit value belonging to others — capturing crypto exchanges, custody providers and DLT-based trading platforms. The framework is principles-based, providing flexibility without sacrificing regulatory credibility.

Nine Core Principles, Practical Supervision

The DLT framework requires licensed firms to demonstrate nine core principles: fitness and propriety of principals; fair treatment of customers; adequate financial resources; effective risk management; sound corporate governance; secure access systems and protocols; financial crime prevention; resilience of IT systems; and maintenance of market integrity. The GFSC takes a proactive, communicative approach to supervision and actively encourages pre-application engagement to streamline the licensing process.

MiCA Positioning

The EU's Markets in Crypto-Assets Regulation (MiCA) has created material compliance complexity for European crypto businesses. Gibraltar, as a British Overseas Territory outside the EU, is not subject to MiCA — but firms with European business need to assess their exposure carefully. Gibraltar's established DLT framework provides a credible, recognised regulatory foundation that supports dialogue with EU counterparts without mandating MiCA compliance.

Tax Efficiency

Gibraltar's 15% territorial corporation tax, absence of capital gains tax and absence of VAT make it a commercially attractive location for crypto businesses. Token issuance, trading revenue and custody income are all assessed under the territorial principle — income arising outside Gibraltar is generally outside scope.

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 in Gibraltar are regulated by the GFSC under the Financial Services (Distributed Ledger Technology Providers) Regulations 2017. Licensed firms must demonstrate continuous compliance with the nine core regulatory principles and are subject to ongoing supervision, periodic inspections and notification obligations for material changes to the business.

There is no regulatory sandbox in Gibraltar in the traditional sense; instead, the GFSC may require firms to undertake a testing phase and a restricted operation phase under regulatory oversight before full licensing. This structured approach allows the GFSC to assess a firm's operations in practice rather than on paper alone.

Token-selling companies and businesses deriving income from the sale of tokenised digital assets are also subject to Gibraltar's Proceeds of Crime Act and associated AML/CTF guidance. Resilience Group's compliance team has direct experience of managing these obligations for DLT-licensed and token-active businesses.

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.