Licensing
Establish which permission you need before you apply for one
Regulators do not assess what a product is called. They assess whether you are carrying on a regulated activity, under which instrument, in which jurisdiction. Getting that sequence right is most of the work.
ZKCAP does not grant permissions. Every authorisation decision belongs to the regulator named against that instrument.
The perimeter question
Where businesses get this wrong
Almost every expensive licensing mistake is a sequencing mistake, not a documentation mistake.
Applying for the wrong permission
Two instruments can look interchangeable from the outside and cover different activities. An application for the wrong one is a wasted cycle, not a near miss.
Perimeter analysis comes before any application effort is spent.
Assuming one jurisdiction's rules travel
The same commercial activity attracts a different instrument, a different regulator and a different requirement set in each jurisdiction.
There is no global requirement set, and this site never presents one.
Operating before the permission exists
Launching on the assumption that an exemption or a partner's permission covers you, without confirming that it actually does.
This is a serious matter that needs legal advice immediately, not a readiness review.
Category discovery
The four published permission families
Each family is expressed through jurisdiction-specific instruments. Open one to see the instrument, the regulator and the requirement areas per jurisdiction.
Money services (MSB)
Moving money for other people: remittance, money transfer, currency exchange and closely related money services.
US · Federal money services business registration plus state money transmitter licensing — US federal financial-crimes authority (registration) and each state banking regulator (licensing)
HK · Money Service Operator (MSO) licence — Customs and Excise Department (Hong Kong)
SG · Payment Services Act licence (money-transfer services) — Monetary Authority of Singapore
Typically needed by
- Cross-border remittance and payout businesses
- Currency exchange and FX services for consumers or businesses
- Platforms that receive customer funds and pay third parties
Usually not needed by
- Businesses that only collect payment for their own goods or services
- Software vendors that never touch customer funds or payment flows
E-money (EMI)
Issuing electronic money or operating payment accounts, where customer balances sit with your business rather than with a bank the customer chose.
SG · Payment Services Act licence (e-money issuance and account issuance) — Monetary Authority of Singapore
HK · Stored Value Facility (SVF) licence — Hong Kong Monetary Authority
Typically needed by
- Wallet and multi-currency account products
- Platforms that hold balances for users between transactions
- Card programme managers issuing on their own permission
Usually not needed by
- Businesses that route payments without ever holding customer balances
- Merchants using a licensed provider's account infrastructure under that provider's permission
Broker / capital markets
Dealing in, arranging or advising on securities and other capital-markets products, or managing money on behalf of clients.
US · Broker-dealer registration and self-regulatory organisation membership — US Securities and Exchange Commission with the relevant self-regulatory organisation and state regulators
SG · Capital Markets Services (CMS) licence — Monetary Authority of Singapore
Typically needed by
- Brokerage and trading platforms offering securities to clients
- Firms arranging investments or introducing clients to counterparties for a fee
- Asset and portfolio managers taking discretionary mandates
Usually not needed by
- Businesses raising capital only for themselves
- Information or analytics products with no dealing, arranging or advising activity
Virtual assets (VASP)
Providing virtual asset services to other people: exchange, transfer, custody, brokerage or platform operation.
SG · Payment Services Act licence (digital payment token services) — Monetary Authority of Singapore
HK · Virtual asset trading platform licence — Securities and Futures Commission (Hong Kong)
AE · Virtual asset service provider licence (zone or emirate-level regime) — The applicable UAE virtual-asset regulator or free-zone financial services authority for the chosen regime
Typically needed by
- Exchanges and trading platforms serving retail or institutional users
- Custody and wallet providers holding customer assets
- Businesses converting between fiat and digital assets for customers
Usually not needed by
- Protocol development with no customer funds, custody or exchange service
- Businesses that only accept digital assets as payment for their own goods, subject to local rules
Jurisdiction comparison
The same activity, a different instrument in each jurisdiction
This is the reason a generic checklist does not work. The instrument name and the regulator are what actually differ.
| Permission family | United States | Hong Kong | Singapore | United Arab Emirates |
|---|---|---|---|---|
| Money services (MSB) | Federal money services business registration plus state money transmitter licensing — US federal financial-crimes authority (registration) and each state banking regulator (licensing) | Money Service Operator (MSO) licence — Customs and Excise Department (Hong Kong) | Payment Services Act licence (money-transfer services) — Monetary Authority of Singapore | Not published |
| E-money (EMI) | Not published | Stored Value Facility (SVF) licence — Hong Kong Monetary Authority | Payment Services Act licence (e-money issuance and account issuance) — Monetary Authority of Singapore | Not published |
| Broker / capital markets | Broker-dealer registration and self-regulatory organisation membership — US Securities and Exchange Commission with the relevant self-regulatory organisation and state regulators | Not published | Capital Markets Services (CMS) licence — Monetary Authority of Singapore | Not published |
| Virtual assets (VASP) | Not published | Virtual asset trading platform licence — Securities and Futures Commission (Hong Kong) | Payment Services Act licence (digital payment token services) — Monetary Authority of Singapore | Virtual asset service provider licence (zone or emirate-level regime) — The applicable UAE virtual-asset regulator or free-zone financial services authority for the chosen regime |
United States
- Money services (MSB)
- Federal money services business registration plus state money transmitter licensing — US federal financial-crimes authority (registration) and each state banking regulator (licensing)
- E-money (EMI)
- Not published
- Broker / capital markets
- Broker-dealer registration and self-regulatory organisation membership — US Securities and Exchange Commission with the relevant self-regulatory organisation and state regulators
- Virtual assets (VASP)
- Not published
Hong Kong
- Money services (MSB)
- Money Service Operator (MSO) licence — Customs and Excise Department (Hong Kong)
- E-money (EMI)
- Stored Value Facility (SVF) licence — Hong Kong Monetary Authority
- Broker / capital markets
- Not published
- Virtual assets (VASP)
- Virtual asset trading platform licence — Securities and Futures Commission (Hong Kong)
Singapore
- Money services (MSB)
- Payment Services Act licence (money-transfer services) — Monetary Authority of Singapore
- E-money (EMI)
- Payment Services Act licence (e-money issuance and account issuance) — Monetary Authority of Singapore
- Broker / capital markets
- Capital Markets Services (CMS) licence — Monetary Authority of Singapore
- Virtual assets (VASP)
- Payment Services Act licence (digital payment token services) — Monetary Authority of Singapore
United Arab Emirates
- Money services (MSB)
- Not published
- E-money (EMI)
- Not published
- Broker / capital markets
- Not published
- Virtual assets (VASP)
- Virtual asset service provider licence (zone or emirate-level regime) — The applicable UAE virtual-asset regulator or free-zone financial services authority for the chosen regime
Capital and own-funds requirements are set by each regulator and are held as platform catalogue data. They are not published on this page, because a figure quoted against the wrong rulebook version is worse than no figure.
Pending legal and catalogue baseline review. This detail is awaiting the platform claims and legal baseline review (ADM-230). It carries no recorded source or as-of date, so it is orientation only — confirm current requirements with the responsible authority.
Requirements
What every regulator examines
The specific rules differ by jurisdiction; the areas assessed are consistent. A readiness assessment works through each of them against your actual position.
Governance and controllers
Who owns and runs the business, the fitness and propriety of each controller, and whether the reporting lines make the arrangement credible.
Financial-crime framework
Customer due diligence, screening, monitoring, reporting and record keeping, proportionate to the model and its geography.
Business plan and projections
A regulator-grade plan whose projections reconcile to the capital and liquidity position you are claiming.
Client money and safeguarding
Where the business holds money belonging to customers, how it is segregated, reconciled and evidenced.
Operational resilience
Information security, change management, outsourcing oversight, continuity and incident reporting.
Local presence and substance
Incorporation, premises, staffing and locally accountable management, which several jurisdictions treat as decisive.
Project model
How a licensing programme runs
A licensing engagement is a project with milestones, document requirements and tracked information requests — not a form submission.
Readiness and gap analysis
YouStructured questions establish which requirement areas you already satisfy and which are open. The result is a gap list, not an assessment of whether a regulator will authorise you.
Scoping with a licensing specialist
Qualified providerA qualified licensing provider reviews the gap list, confirms the target permission and scopes the work into a proposal.
Application programme
Qualified providerPolicies, governance arrangements, controls documentation and the application pack are produced against the regulator's published requirements, tracked as milestones with document requirements.
Submission to the regulator
Qualified providerThe provider submits the application and records the submission evidence. From this point the state shown reflects the regulator's position.
Regulatory assessment
External authorityOutcome not controlled by ZKCAPThe regulator reviews the application and normally raises information requests. Each request appears as a first-class item with a response path, not as an email thread.
Determination
External authorityOutcome not controlled by ZKCAPThe regulator authorises, refuses, or authorises with conditions or limitations. The platform records whichever determination is issued, including refusal and its remediation path.
Ongoing supervision and renewals
External authorityOutcome not controlled by ZKCAPAuthorisation begins a supervisory relationship: reporting, notifications, attestations and periodic fees become tracked obligations.
If the answer is no
Refusals, conditions and changing requirements
These outcomes are normal in licensing, and each has a defined path.
- If this happens
The regulator raises information requests
Each request becomes a tracked item with an owner and a due date. Responses are kept consistent with what was already submitted, which is where applications most often come apart.
- If this happens
The application is refused
The reasons are recorded and assessed. Remediation, a different permission, or a different jurisdiction becomes the next decision — not an immediate re-application.
- If this happens
Authorisation is granted with conditions
Conditions and limitations are recorded as obligations, because they constrain what the business may actually do from day one.
- If this happens
Requirements change mid-application
Rulebook changes are mapped onto the open application, and their impact on the submitted pack is surfaced rather than absorbed silently.
Boundary
Who is responsible, and who decides
Stated once, plainly, so nothing on this page can be read as a promise the platform cannot keep.
Providers
Who does the work
Readiness assessment, the application programme and regulator engagement are delivered by a verified licensing specialist. Their verification state and verified credentials are shown on their profile.
Start
Begin with the readiness assessment
It compares your current position against the areas a regulator examines and produces a gap list. It is not an application, and it does not indicate whether a regulator would authorise you.
- Start assessment
Money services (MSB)
3 published jurisdictions
- Start assessment
E-money (EMI)
2 published jurisdictions
- Start assessment
Broker / capital markets
2 published jurisdictions
- Start assessment
Virtual assets (VASP)
3 published jurisdictions
A readiness assessment is not an application.