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ZKCAPZKCAP — global business and capital infrastructure

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.

  1. 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
  2. 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
  3. 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
  4. 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.

  • 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.

  1. Readiness and gap analysis

    You

    Structured 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.

  2. Scoping with a licensing specialist

    Qualified provider

    A qualified licensing provider reviews the gap list, confirms the target permission and scopes the work into a proposal.

  3. Application programme

    Qualified provider

    Policies, governance arrangements, controls documentation and the application pack are produced against the regulator's published requirements, tracked as milestones with document requirements.

  4. Submission to the regulator

    Qualified provider

    The provider submits the application and records the submission evidence. From this point the state shown reflects the regulator's position.

  5. Regulatory assessment

    External authorityOutcome not controlled by ZKCAP

    The 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.

  6. Determination

    External authorityOutcome not controlled by ZKCAP

    The regulator authorises, refuses, or authorises with conditions or limitations. The platform records whichever determination is issued, including refusal and its remediation path.

  7. Ongoing supervision and renewals

    External authorityOutcome not controlled by ZKCAP

    Authorisation 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.

A readiness assessment is not an application.