A licence sounds like paperwork. A certificate on a wall, a number on a website, something a company obtains and then forgets about.

It is not that. In financial services, a licence is the instrument through which a regulator decides how a firm may behave: whether customer money must be held separately from the firm’s own funds, what the firm must disclose and how often, how much capital it must hold against what it does, and which authority supervises it. The licence is where those obligations attach. Without one, none of them do.

That is why a quiet but consequential shift is under way across Asia. Governments are writing licensing regimes for digital assets — and firms are beginning to apply for them.

Bhutan writes a rulebook

In southern Bhutan, the Gelephu Mindfulness City Special Administrative Region has established a financial services and virtual asset regime under its Financial Services Act 2025, administered by the Gelephu Financial Services Office. Any firm carrying on regulated financial or virtual asset activity in or from the zone must hold a Financial Services Licence.

“Our objective is to build a world-class digital asset ecosystem founded on robust regulation, institutional standards and long-term economic value,” said Jigdrel Singay, Board Director of Gelephu Mindfulness City.

On 6 August, the digital asset exchange Bitget signed a cooperation agreement with the Gelephu Mindfulness City Authority, setting out a framework to establish a legal presence in the zone and prepare a licence application. No licence has been granted. What the agreement commits the company to is the process itself — a process that did not exist two years ago.

“Bhutan is approaching digital assets with a rare mix of long-term thinking, clean-energy advantage and regulatory clarity,” said Gracy Chen, chief executive of Bitget. The country has used hydropower to support digital asset mining as part of a wider strategy to create employment and retain young talent.

The agreement contemplates local hiring and an office presence over time, which the zone’s authority frames as part of a wider focus on talent development and knowledge transfer rather than market access alone. “Partners such as Bitget play an important role in bringing global expertise while contributing to the development of local capabilities and the broader financial ecosystem,” Singay said.

A regional pattern

“Recent regulatory developments across Pakistan, Japan and the United States suggest crypto is moving further into a coordinated phase of policy normalization across both emerging and developed markets,” wrote Ryan Lee, chief analyst at Bitget Research, in commentary published in April. As more jurisdictions define licensing, tax treatment and disclosure standards, he argued, exchanges gain more predictable operating conditions.

The direction is not uniformly permissive. Argentina introduced a registration regime for virtual asset service providers. Elsewhere in Southeast Asia, regulators have issued cease-and-desist orders against exchanges operating without authorisation. A licensing regime decides who may operate; it also decides who may not.

Cambodia is drafting its own

On 8 July, Prime Minister Hun Manet signed a decision, made public on 10 August, establishing an Inter-Ministerial Working Group responsible for preparing and drafting a law on the management of virtual and digital assets. The group has 26 members, co-chaired by a Secretary of State at the Ministry of Economy and Finance and a Deputy Governor of the National Bank of Cambodia.

Its remit, set out in the decision, is to study relevant domestic and international law and practice, hold consultations with stakeholders, and produce draft legislation described as coherent, comprehensive and capable of being implemented effectively — including mechanisms for investor protection and the rights and obligations of users.

Some rules already apply, and they reach further into ordinary banking than most people realise. Prakas B7-024-735 Prokor, issued in December 2024 and signed by Governor Chea Serey, sorts cryptoassets into two groups and limits how much of either a licensed Cambodian bank may hold against its own capital. That is a rule about what a bank may do with its balance sheet, and it exists now. On 6 August the National Bank added a further requirement, obliging businesses that issue electronic money for payments within a single network to notify the regulator before operating.

On 17 August, Governor Chea Serey met the United States Chargé d’Affaires in Phnom Penh. Discussions covered macroeconomic developments and financial stability, and included potential technical assistance on virtual asset legislation and regulation.

What is still undecided

A great deal. Cambodia’s working group has been formed, but the law has not been drafted. It is not yet known which categories of digital asset will fall inside it, what a licence will require of the firms that hold one, or what obligations will attach. Bhutan’s regime exists on paper, and the applications made under it have yet to be decided. A framework announced is not a framework in force.

What can be said is that the question has changed. For much of the past decade the debate across the region was whether digital assets should be permitted at all. It is now a narrower and more technical argument about what a licence should require — which is the argument regulators have been having about banks, insurers and brokers for the better part of a century.

Key terms
Licence	Official permission from a regulator to provide a financial service. It is the point at which obligations attach — how customer money is held, what must be disclosed, how much capital must be maintained, and which authority supervises the firm.
Client asset segregation	A requirement that customer money is held separately from the firm’s own funds, so the two are never mixed. A common licence condition in regulated financial services.
Cryptoassets	The term used by the National Bank of Cambodia in Prakas B7-024-735 Prokor (Khmer: ទ្រព្យសកម្មគ្រីបតូ). The law now being drafted uses “virtual assets” and “digital assets”.

This article is provided for general information only and does not constitute financial or investment advice. Digital asset services in Cambodia are regulated by the National Bank of Cambodia under Prakas B7-024-735 Prokor on Transaction Related to Cryptoassets. Readers should seek independent professional advice before making financial decisions.