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Bullish’s Gibraltar license – Q&A with our Head of Compliance and Risk

Insights Dec 6, 2021 3 min read

Bullish (GI) Limited recently received a Distributed Ledger Technology (DLT) license from the Gibraltar Financial Services Commission (GFSC), for its regulated crypto currency exchange to start taking on institutional and advanced retail customers, who will be able to trade, earn and invest securely.

We caught up with Anthony Smith, Head of Compliance and Risk for the Bullish exchange, on some commonly asked questions relating to the licensing.

1. Why did Bullish apply for the  Distributed Ledger Technology (DLT) license in Gibraltar?

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So ultimately we assessed several jurisdictions before choosing Gibraltar and I think it’s important to note that we specifically mapped our own business considerations to the various regulatory frameworks that we were looking at and then we looked at which regulator would be able to offer us a crypto native if I can call it that licensing regime. Specific to cryptocurrency rather than trying to fit it into an existing regulatory framework.

We also looked at things like time to market, and ultimately we came up with the fact that the GFSC or the Gibraltar Financial Services Commission has an established track record in approving and supervising crypto exchanges which is a huge plus for us in the decision.

Also they are heavily focused on protecting customers, and they have strong regulation in areas such as privacy and financial crime legislation which is really important to us as an exchange. 

It’s a principles based regime which gives us the outcomes of what the regulation wants to achieve, rather than telling us how to do it, and so it does allow some flexibility in the way in which regulated firms are able to apply the legislation to their particular business framework.

We do want to become a global exchange operating in as many jurisdictions as possible and that fit within our risk appetite

Anthony Smith

Head of Compliance and Risk for the Bullish exchange

2. What is next for Bullish now that it has received the DLT license?

Different to other exchanges that typically start their life out as an unregulated business and seek to become regulated, Bullish has chosen to be regulated from the word go. And to ensure that we’re able to continue as a regulated exchange, we need to make sure that our procedures are operating as we have promised and as we have intended. Ultimately though we do want to become a global exchange operating in as many jurisdictions as possible and that fit within our risk appetite. But we will do this in as compliant and legal manner as necessary by obtaining the required licenses in those jurisdictions.

3. Bullish has gone "live" with select institutional customers. What makes the platform different from existing exchanges and what can users expect?

Ultimately the exchange has been designed to integrate a regulated exchange operating a high performance Central Limit Order Book matching engine with a DeFi based architecture. It’s this unique hybrid order book that is underpinned by deep liquidity pools for each trading pair. By combining deep liquidity, automated market making and industry leading security and compliance, we’ve increased the accessibility and efficiency of digital assets for investors.

4. What does Bullish need clients to do for its KYC/AML procedures?

So in line with the Gibraltar Financial Services Commission’s principles, one of which covers financial crime, and the FATF or the Financial Action Task Force requirements, customers can expect to go through the usual Know Your Customer, Anti Money Laundering procedures that they typically experience with other financial institutions. As part of this they can expect for their information to be reviewed and regularly updated and to be, to have to provide us with ongoing information, as and when required. 

I think it’s safe to say that this is probably one of the areas where we have invested most heavily in from our compliance program. Given the importance of it to global governments and regulators in abolishing the scourge of financial crime and fraud. And so we really want to play our part in that as a responsible financial services organization, and we will really ensure that we apply global leading practices in this regard. 

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