2026 Authoritative Guide

Bhutan in 2026
Traditional financial and Web3 regulatory policies
Compliance Guidelines

In-depth analysis of Bhutan's unique dual-track regulatory framework, the legal framework of Greppe Mindfulness City (GMC), and the deployment opportunities for global Web3 enterprises.

3

The world's third largest holder of BTC

0%

GMC Corporate Income Tax Rate

5+

Approved international companies

100%

Renewable energy power supply

Global Positioning

Bhutan's Position in the Global Web3 Regulatory Landscape

From the heart of Asia to emerging crypto jurisdictions

Sovereign Bitcoin Reserve

The world's third-largest sovereign Bitcoin holder announced in 2025 an investment of $10 billion in GMC development.

Advantages of clean energy

Abundant hydropower resources, in cooperation with international giants such as Bitdeer, to digitize energy exports.

Dual-track regulation

Onshore, the GMC Special Administrative Region strictly protects monetary sovereignty, adopting Singapore law plus ADGM rules.

Zero tax policy

GMC companies have a 0% corporate income tax rate and a 0% capital gains tax rate (subject to meeting the requirement of substantial business operations).

Asian time zone advantage

Located in the heart of the Asia-Pacific region, it is convenient to serve the Chinese, Indian, and Southeast Asian markets.

National-level support

Direct government involvement (DHI, DK Bank), long-term commitment to Web3 development

Detailed framework

Bhutan Financial and Web3 Regulatory Framework

In-depth analysis of the legal basis, mechanism design and practical application of the dual regulatory system

Central Bank Powers

The Royal Monetary Authority of Bhutan (RMA) functions as a central bank under the Royal Monetary Authority Act 2010. Its primary objective is to formulate and implement monetary policy to achieve and maintain price stability, rather than economic growth.

The RMA holds an extremely cautious attitude towards the volatility of crypto assets.

BTN is pegged to INR at a 1:1 ratio, requiring sufficient foreign exchange reserves to be maintained.

Residents are prohibited from converting BTN to US dollars via cryptocurrency in order to protect the currency's anchor.

Financial Services Act 2011

This is the "constitution" of Bhutan's onshore financial supervision, which establishes a comprehensive licensing system covering banking, insurance, securities and "other financial services".

Section 122 adopts an open definition, and the RMA has the authority to classify any activity involving fund management as a regulated service.

Article 11 stipulates extremely stringent fitness and proper requirements for senior executives and major shareholders.

Article 14 requires that any transaction resulting in a change of control must obtain prior written approval from the RMA.

Core compliance and risk control functions must not be outsourced.

Foreign exchange controls and capital flows

The Foreign Exchange Rules and Regulations 2020 (FERR 2020) clearly distinguishes between current account items and capital account items.

Current account: Payments for imported goods and services are relatively free.

Capital account: Strictly regulated; any overseas investment or securities investment requires RMA approval on a case-by-case basis.

The "foreign exchange balance" requirement states that FDI companies must generate sufficient dollar revenue to remit dollar profits.

Onshore vs GMC comparison

Dimensions Onshore system GMC Special Zone
Legal system Civil Law System Common Law (Singapore + ADGM)
regulatory agency RMA, MoICE GMCA
Encryption Policy Prohibited (Tourism Exception) Permitted (FSP license required)
corporate income tax 25-30% 0%
Foreign exchange controls Strict control 自由
Target companies Traditional industries, tourism, BPO Web3, Fintech, DeFi

legal basis

The Royal Charter issued in February 2024 granted the GMC executive, legislative, and judicial autonomy. The core of the GMC Act of 2024 (the Applicable Law Act) is “legal transplantation.”

Royal charters hold extremely high legal force in Bhutan's constitutional system, even surpassing ordinary parliamentary legislation in certain areas.

GMC did not draft laws from scratch, but instead directly "adopted" mature laws that had been proven in the international market.

Singapore laws (18 in total) are adopted.

GMC directly adopts Singapore law as its civil and commercial basis:

Singapore laws applied:

The Companies Act 1967 – The Cornerstone of Company Formation, Governance, and Shareholding Structure

The Bankruptcy, Reorganization and Dissolution Act 2018 – crucial for cryptocurrency exchanges, providing a mature bankruptcy law claim.

Electronic Transactions Act 2010 – Clarifies the legal effect of electronic signatures and smart contracts

Contracts (Third-Party Rights) Act 2007 – Enhancing the flexibility of commercial contracts

Personal Data Protection Act 2012 – PDPA Data Privacy Protection

The ADGM rules adopted (10 parts)

At the financial oversight level, GMC directly adopted the entire set of rules from the Abu Dhabi Global Market (ADGM):

ADGM rules:

The Financial Services and Markets Ordinance 2015 defines regulated activities and requires a Financial Services License (FSP).

Anti-Money Laundering and Sanctions Rules – VASPs must fulfill AML obligations equal to or even more stringent than those of traditional banks.

Market Infrastructure Rules – Addressing exchange matching engines, clearing and settlement, and capital adequacy requirements.

tax incentives

Unlike the 30% corporate income tax onshore, GMC implements a zero-tax policy:

Capital gains tax: 0%

Individual income tax: Tax exemption may be available for foreign talents.

Substantive requirements: There must be a physical office, local staff, and operating expenses within the GMC.

Onshore vs GMC comparison

Dimensions Onshore system GMC Special Zone
Legal system Civil Law System Common Law (Singapore + ADGM)
regulatory agency RMA, MoICE GMCA
Encryption Policy Prohibited (Tourism Exception) Permitted (FSP license required)
corporate income tax 25-30% 0%
Foreign exchange controls Strict control 自由
Target companies Traditional industries, tourism, BPO Web3, Fintech, DeFi
Practical Guide

Practitioner's Guide

Market access pathways and license applications

Market access path selection

Path A: Onshore FDI Company (Thimphu)

Business scope
Pure software development, data center construction, BPO services

Legal system
Bhutan Companies Act 2016 (a civil law hybrid law)

regulatory agency
Ministry of Economic Affairs of Bhutan (MoICE) + RMA

Encryption Policy

Holding, trading, and issuing tokens are strictly prohibited.

Foreign exchange controls
Strict regulations, requiring case-by-case approval, and sometimes time delays.

corporate income tax
25%-30% corporate income tax

Path B: GMC Special Economic Zone Company (Gelephu)

Business scope
Cryptocurrency exchanges, projects that raise funds through tokens, DAOs, asset management funds

Legal system
Singapore Companies Act 1967 (Common Law)

regulatory agency
GMC Authority (GMCA)

Encryption Policy

Permitted (FSP license required)

Foreign exchange controls
Freedom, multi-currency accounts, supports stablecoins

corporate income tax
0% (substantial business operations required)

Complete Guide to GMC FSP License Application

This article provides an in-depth analysis of the entire process, requirements, required documents, and timeline for applying for a Financial Services License (FSP) in the Greppe Mindfulness City (GMC) Special Economic Zone. A one-stop guide from basic concepts to successful approval.

What is FSP?

Financial Services License Basics

An FSP (Financial Services Permission) is the authorization required to conduct financial services activities within the GMC Special Economic Zone. Under the Financial Services and Markets Regulations 2015 (FSMR), operating an exchange, custody, or brokerage business requires an FSP license. This is central to the GMC regulatory framework, ensuring all financial services providers meet international standards.

Financial Services Applicable to FSP

Exchanges: Crypto asset trading platforms, spot trading, futures trading

Custodians: Digital asset custody services, cold wallet management, multi-signature management

Brokers: Crypto asset brokerage services, OTC trading, market makers

Other financial services: payment services, clearing and settlement, asset management

Legal framework

GMC adopts the 18 Singapore legal systems

GMC adopted a proven Singaporean legal framework, which is widely recognized and practiced in international financial markets. This legal transplantation strategy ensures that GMC's regulatory framework is aligned with international best practices.

The Companies Act 1967

The foundation for company formation, governance, and equity structure. Supports complex structures such as Variable Interest Entities (VIEs), providing international companies with flexible organizational forms.

Bankruptcy Law 2018

This is crucial for cryptocurrency exchanges. In the event of bankruptcy, creditors can assert their rights under Singapore's mature bankruptcy law to protect user assets.

Electronic Transactions Act 2010

The legal effect of electronic signatures and smart contracts has been clarified, providing a legal basis for on-chain governance and automated transactions.

ADGM Financial Rules

The entire set of rules, including Abu Bibi's global market rules such as FSMR and AML/anti-money laundering rules, was directly adopted to ensure consistency with international standards.

Capital adequacy ratio requirements

Minimum capital requirements:Depending on the type and size of the business, the capital requirement is typically between $100 million and $500 million. For exchange-related businesses, higher capital is usually required.

Capital adequacy ratio:Based on risk-weighted assets, this is typically no less than 8%. This ensures that companies have sufficient buffers to cope with market risks.

Capital calculation method

Capital adequacy ratio = (Core capital / Risk-weighted assets) × 100%

Risk-weighted assets include: counterparty risk, market risk, operational risk, etc.

Management team requirements

The GMC requires key management personnel in companies to have relevant industry experience and professional qualifications. These personnel will report directly to the GMC regulatory body.

Chief Executive Officer (CEO)

Must have 5+ years of experience in the financial services industry, or 3+ years of experience in the crypto/blockchain industry.

Chief Compliance Officer (CCO)

Must have at least 3 years of experience in financial compliance and be familiar with AML/KYC processes and anti-money laundering rules.

Chief Risk Officer (CRO)

Must have at least 3 years of risk management experience and be able to identify and assess market, credit, and liquidity risks.

Chief Technology Officer (CTO)

Must have 3+ years of technical management experience and be familiar with trading systems, security architecture, and data protection.

Technical infrastructure requirements

System Availability

99.9% or more

Data security certification

ISO 27001 or equivalent

Business Continuity RTO

≤ 4 hours

Business Continuity RPO

≤ 1 hours

DDoS protection capabilities

≥ 100Gbps

Compliance requirements

AML/KYC: Customer due diligence and ongoing monitoring must be implemented, including identity verification, investigation of the source of funds, and identification of beneficial owners.

Anti-Money Laundering Report: Report suspicious transactions to GMC monthly, including transaction amount, counterparty, and transaction type.

Financial Reporting: Report financial status to GMC quarterly, including balance sheet, income statement, and risk indicators.

Audit Report: An independent auditor is engaged annually to conduct an audit and submit an audit report to GMC.

Risk Management: Establish a sound risk management framework and conduct regular stress tests and risk assessments.

Application materials list

Company Documents

  • Company registration certificate and business license
  • Articles of Association and bylaws
  • Explanation of equity structure and list of shareholders
  • Board resolutions and authorization documents
  • Company organizational chart

Compliance Documents

  • AML/KYC Policy and Process Documents
  • Anti-money laundering and sanctions compliance rules
  • Risk management framework and policies
  • Internal audit plan and report
  • Employee training records and compliance manual
  • Data protection and privacy policy

Technical documents

  • System architecture description and technical documents
  • Security audit report (audited by a third party)
  • Business continuity and disaster recovery plan
  • Network security protection measures instructions
  • Data backup and recovery process
  • System test report and performance indicators

Financial and Management Documents

  • Capital adequacy ratio proof and financial statements
  • Audit report (if any)
  • Proof of insurance (including online insurance, liability insurance, etc.)
  • Management team resumes and qualifications
  • Certificate of no criminal record

Pre-application preparation stage

Company Establishment and Registration

Register the company with GMC and obtain the Certificate of Incorporation. Determine the equity structure and governance framework, and clearly define the directors, shareholders, and management.

Compliance system construction

Establish AML/KYC processes, anti-money laundering policies, risk management frameworks, and internal audit mechanisms. Develop employee training plans and compliance manuals.

Technical infrastructure development

Deploy trading, custody, and clearing systems. Implement security measures, DDoS protection, and data encryption. Establish disaster recovery and resilience mechanisms.

Hire a professional consultant

We have hired legal, compliance, and technical advisors with experience in GMC applications. They will guide you through the entire application process.

Application review stage

Phase 1: Preliminary review (1-2 weeks)

Upon receiving the application, GMC conducts a completeness check and formal review of the materials. It confirms that all required documents have been submitted and that the format meets the requirements.

Phase Two: Substantive Examination (4-8 weeks)

GMC's regulatory body conducts a thorough evaluation of the application. This includes assessing the compliance system, reviewing the technical infrastructure, evaluating the qualifications of the management team, and verifying the capital adequacy ratio.

Phase 3: On-site inspection (optional, 1-2 weeks)

GMC may conduct on-site visits to key departments to verify that the systems and processes conform to the description in the application documents.

Phase Four: License Issuance

Upon approval, GMC issues an FSP license. This clearly defines regulatory obligations, reporting requirements, and ongoing compliance requirements.

Common reasons for rejection and how to deal with them

Inadequate compliance system:The AML/KYC process is not in compliance with requirements. Solution: Hire a compliance consultant and develop detailed compliance process documentation.

Technical infrastructure does not meet standards:The system lacks security or availability. Solution: Conduct a third-party security audit to improve system availability.

Management team qualifications not met:Key management personnel lack experience. Solution: Adjust the management team and hire personnel with relevant experience.

Insufficient capital:The minimum capital requirement has not been met. Solution: Increase capital investment and provide proof of capital adequacy.

Suggestions for expediting the application process

Communicate in advance:Before making a formal application, communicate with the GMC regulatory authority to understand the specific requirements.

Complete the information:Ensure all application materials are complete, accurate, and professional. The quality of the materials directly affects the processing speed.

Hiring consultants:Hire legal and compliance advisors with experience in GMC applications, as they understand the GMC approval criteria.

Parallel advancement:While awaiting approval, we will promote technology development and market preparation to strive for a rapid launch.

Full schedule

Company Establishment and Registration

1-2 weeks

Compliance system construction

4-8 weeks

Technology Development and Testing

8-16 weeks

Application material preparation

2-4 weeks

FSP Application Review

4-8 weeks

Total

4-6 months

Expedited application

If time is tight, you can apply for expedited processing. Expedited processing can usually shorten the processing time to 2-3 months, but it requires an additional fee and ensures that all documents fully meet the requirements.

Post-approval continuing obligations

Regular report

  • Monthly Report: Transaction Volume, Number of Users, Suspicious Transactions
  • Quarterly Report: Financial Status, Risk Indicators, Compliance Status
  • Annual Reports: Audit Report, Compliance Report, Strategic Planning

Continuous Compliance

  • Policy Update: Update the AML/KYC policy according to the supervisor's requirements.
  • Employee training: Conduct compliance training and updates regularly.
  • System upgrade: Upgrade technical systems and security protection as needed.
  • Risk assessment: Conduct risk assessments and stress tests regularly.

Change Notice

  • Change of directors: Notify GMC within 30 days
  • Equity change: Approval from GMC obtained prior to the change.
  • Change of business scope: Application for revision of FSP license
  • Major incidents: Notify GMC immediately (e.g., security incidents, financial difficulties).

Bank accounts and funding channels

Despite the GMC's permission for crypto-related businesses, the global banking industry still engages in de-risking crypto-related activities.

DK Bank is currently the most reliable fiat-to-cryptocurrency gateway; you should establish a relationship with them as soon as possible.

Correspondent Banking Risk exists; USD clearing relies on upstream corresponding banks.

Maintaining diversified stablecoin settlement channels is a necessary risk control measure.

Corporate layout

Bhutan Web3 Enterprise Ecosystem Map

Distribution and business scope of major approved and operating entities

Regional Overview

Gelephu (GMC Special Zone)

Grep Mindfulness City, a hub for Web3 enterprises

Special Administrative Region

3 company

Thimphu (Capital City)

Onshore Supervision Center, DK Bank Headquarters

On shore

1 company

Gedu/Jigmeling

Mining base, energy-intensive industry

能源

1 company

Company Details

Matrixport

⌖ Gelephu (GMC)
A leading global provider of virtual asset financial services

Approved
Service scope:
Virtual asset trading Hosting services asset Management

OxPay Financial

⌖ Gelephu (GMC)
A Singapore-listed company (SGX: TVV) focusing on crypto payments.

Approved
Service scope:
Crypto payments B2B services Financial Services

MatrixDock

⌖ Gelephu (GMC)
A leader in gold tokenization, advancing RWA applications.

In cooperation
Service scope:
Asset tokenization RWA Design Blockchain Applications

DK Bank

Thimphu (On Shore)
Bhutanese local digital bank, fiat-crypto channel

In operation
Service scope:
Fiat currency deposits and withdrawals Payment and settlement BinancePay

Bitdeer & DHI

⌖ Gedu/Jigmeling
Nasdaq-listed Bitdeer partners with DHI for Bitcoin mining.

In operation
Service scope:
bitcoin mining infrastructure Energy optimization

Ecological statistics

5+

Approved/Operating Companies

3

Major regions

3

GMC Special Zone Enterprises

2025

Year of rapid development

Investment Opportunities

Bhutan's Web3 ecosystem is in a phase of rapid development. The zero-tax policy, legal certainty, and national-level support offered by the GMC Special Economic Zone have attracted top global institutions. Whether it's exchanges, asset management funds, or infrastructure providers, there is ample market space and policy support.

Aiying's team can assist companies in completing market assessments, legal due diligence, license applications, and compliance system establishment.

Special measures

National-level strategy and innovation experiment

Sovereign mining strategies and Web3 native payment systems

National-level mining strategy

New Forms of Sovereign Wealth

DHI and Bitdeer's Cooperation Framework

The partnership between DHI and Nasdaq-listed Bitdeer is a prime example of sovereign mining.

Legal Entity: The two parties established a joint venture company (such as Bitdeer Gedu Private Limited), registered in accordance with the Bhutan Companies Act 2016.

Asset Leasing: DHI leases land in Gedu and Jigmeling to a joint venture to build a data center.

Power Purchase Agreement (PPA): The joint venture needs to sign a PPA with Bhutan Electric Power Corporation (BPC), which is the most crucial legal document.

"Power Abandonment Clauses" and Operational Risks

During the dry winter season, if Bhutan experiences a power shortage, mines must unconditionally reduce their load or even shut down to ensure electricity supply for residents.

This is listed as a significant operational risk in the prospectus and risk disclosure.

This reflects the Bhutanese government's priority on energy security.

Mines need to establish flexible operating mechanisms to cope with seasonal changes.

Tourism Payment Exception

Binance Pay and DK Bank's closed-loop experiment

Operational process:

Foreign tourists can use wallets such as Binance Pay to pay Bhutanese merchants in BTC/ETH/USDT.

Payment instructions are issued through Binance → DK Bank receives crypto assets as the acquiring bank.

DK Bank instantly converts it to fiat currency (BTN/INR) in the background through liquidity providers (LPs).

Merchant accounts receive fiat currency

Compliance characteristics: This is a "closed-loop" system. Merchants and ordinary Bhutanese citizens never hold crypto assets; the risk is entirely borne by DK Bank and overseas limited partners (LPs). This satisfies the needs of tourists without violating the RMA's bottom line of "prohibiting residents from holding foreign exchange/virtual assets."

Sovereign wealth creation

By converting surplus hydroelectric energy into Bitcoin through mining, the nation can digitize its energy exports and accumulate wealth.

Firewall mechanism

Encryption is prohibited onshore, but permitted by GMC, which uses a closed-loop system to ensure that encryption risks do not spread to the domestic financial system.

Web3 native

Digital identity, smart contracts, DeFi and other technologies have gained full legal recognition and regulatory framework in GMC.

key data

40+

Relevant laws and regulations

18 + 10

Singapore laws and ADGM rules adopted

February, 2024

Royal Charter

February, 2025

RMA issues circular on tiered management of crypto assets

3

Global ranking of sovereign Bitcoin holders

10,000 BTC

GMC Development Commitment

Conclusions and Outlook

Bhutan's financial and Web3 regulatory framework demonstrates the pinnacle of wisdom a small country can achieve in the digital age. Instead of blindly opening up, it has achieved a delicate balance through a "dual-track system": onshore, it strictly adheres to the bottom line of monetary sovereignty and leverages its hydropower advantage to accumulate national wealth through mining; offshore (GMC), it has created a low-friction, high-certainty capital safe haven by fully adopting world-class laws.

For legal and compliance professionals, Bhutan is no longer just a country for tourism, but an emerging "crypto jurisdiction."

For legal and compliance professionals, Bhutan is no longer just a country for tourism, but an emerging "crypto jurisdiction."

For legal and compliance professionals, Bhutan is no longer just a country for tourism, but an emerging "crypto jurisdiction."

Key points to observe in the future

  • GMC's execution capabilities: Can it process license applications efficiently? Can the court system adjudicate cases as independently and professionally as promised?
  • International Recognition: Assessments of Bhutan's dual-track system by international organizations such as the FATF and IMF.
  • Ecosystem maturity: The time lag between license approval and actual commercial operation
  • Policy stability: The legal effect of royal charters during periods of regime change