GIBRALTAR Law and Practice Contributed by: Aaron Payas, Jeremy Requena, Jerome Compson and Reece Atkinson, Hassans
Hassans Madison Building Midtown Queensway Gibraltar GX11 1AA Tel: +34 956785299 Email: info@hassans.es Web: www.gibraltarlaw.com
1. Overview of Blockchain and Crypto- Assets 1.1 Blockchain 1.1.1 Evolution of Uses of Blockchain Blockchain in Gibraltar Gibraltar was an early mover in blockchain regulation, introducing its Distributed Ledger Technology Frame- work (the “DLT Framework”) in October 2017, which came into force on 1 January 2018. This made Gibraltar the first jurisdiction to implement a dedicated regulatory regime for firms using DLT to store or transmit value belonging to others, over- seen by the Gibraltar Financial Services Commission (GFSC). The Framework, which is governed under the Finan- cial Services Act 2019 (FSA) and the Financial Ser- vices (DLT Providers and VAA Providers Regulations 2020 (the DLT Regulations), was designed as a prin- ciples-based and innovation friendly regime, centred on authorisation of DLT Providers such as exchanges, custodians, and remittance firms. Alongside this, Gibraltar developed a parallel anti- money laundering regime tailored to crypto-assets under the Proceeds of Crime Act 2015 (Relevant Financial Business) (Registration) Regulations 2021 (the “RFB Regulations”). This requires virtual asset service providers that fall outside the DLT licensing perimeter to register and comply with AML and CFT obligations (the “POCA Registration”).
The Framework has evolved into a dual system com- bining full authorisation for custodial or value trans- mitting firms and POCA Registration for other crypto- asset activities, allowing flexible but comprehensive regulatory coverage. Gibraltar has continued to position itself as a leading regulated blockchain hub through its DLT Framework and POCA Registration, overseen by the GFSC. Over the past 12 months, the focus has been on refin- ing rather than reinventing the DLT Framework and POCA Registration requirement, with updated guid- ance clarifying licensing boundaries between DLT Pro- viders, virtual asset arrangement providers (VAAPs), and virtual asset service providers (VASPs). Recent reforms in 2025 expanded the regulation of VAAPs and strengthened alignment with global stand- ards such as FATF guidance, bringing VAAPs within the DLT Framework. Token issuers that issue or sell their own native token remain within the POCA Registration regime, but enti- ties that make arrangements in virtual assets are now brought squarely within the scope of the DLT Frame- work. In 2026, the GFSC is working to transition firms from registration under the RFB Regulations to licensing under the DLT Regulations. Current Use Cases The most common blockchain use cases in Gibral- tar continue to be driven by financial services. These
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