Information Bulletin - DAB Application Process (February 2024)

Summary

This Information Bulletin from the Bermuda Monetary Authority (BMA) explains the licence application process and documentation requirements for prospective Digital Asset Business (DAB) applicants under the Digital Asset Business Act 2018. It describes the role of the sector-specific Assessment and Licensing Committee (ALC) and sets out submission logistics, fees, and expected review timelines.

• Submission deadline: Completed applications must be received by 5:00 p.m. on the relevant Thursday to be considered by the ALC four weeks later; late submissions may delay review.
• Submission method: Applications must be emailed to FinTech@bma.bm (no hard copies), with all documents provided in English, using the correct form for the licence class sought (T test licence, M modified licence, or F full licence).
• Missing documentation: If required documents are unavailable or inapplicable, a written explanation must be provided; incomplete applications may be deferred or deemed insufficient.
• Application fees: Fees must be paid concurrently with the application: $1,000 for a T licence, $2,266 for an M licence, and $2,266 for an F licence, payable via specified domestic or international payment channels.
• Post-filing timeline: Applicants can expect: confirmation of receipt and case manager assignment within two business days; confirmation of completeness or list of missing documents within three business days; case manager contact within ten business days; and, if complete, presentation to the ALC within twenty business days following the first Friday after receipt.

The ALC, which meets weekly, may approve, defer, decline, or approve subject to conditions. A complete application does not guarantee approval; applicants must also meet the minimum licensing criteria under DABA and the DABA Statement of Principles.

Key obligations

• Submit completed DAB applications to the Authority no later than 5:00 p.m. on the relevant Thursday to be considered by the ALC four weeks later
• Email applications to FinTech@bma.bm using the correct application form for the licence class sought (T, M, or F), with no hard copies required
• Provide all application documents in English
• Provide a written explanation for any required documentation that is not submitted or is inapplicable
• Pay the applicable application fee (T: $1,000, M: $2,266, F: $2,266) concurrently with the application, ensuring the full fee amount reaches the Authority

Applies to

Digital Asset Business (DAB) applicants, prospective digital asset business licensees

Deadlines

• 5:00 p.m. on the relevant Thursday: Deadline for completed applications to be received for consideration by the ALC four weeks later
• Within two business days: Authority sends confirmation of application receipt and case manager assignment
• Within three business days: Authority confirms whether the application is complete or specifies missing documents
• Within 10 business days: Case manager contacts applicant to discuss the application and substantive review questions
• Within 20 business days following the first Friday after the application is received: Complete applications are presented to the ALC for a decision