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Edit: Gibraltar

Retail_Trading_Status

Current: Allowed-Regulated

Unknown

Initial Research

Status & Confidence

Regulatory Status

Confidence Level

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Executive Summary

Key Pillars

Landmark Laws

*   **Financial Services (Distributed Ledger Technology) Regulations 2017:** Effective January 1, 2018, requiring firms using DLT for storing or transmitting value belonging to others to be authorized by the GFSC as a DLT Provider.
*   **Proceeds of Crime Act 2015 (POCA):** Requires firms to adhere to AML/CFT/CPF compliance, including customer due diligence (CDD), transaction monitoring, and reporting suspicious activities.
*   **Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021:** Implements the FATF's 'travel rule', mandating the collection and exchange of information for virtual asset transfers above a certain threshold.
*   **Proceeds of Crime Act 2015 (Relevant Financial Business) (Registration) Regulations 2021:** Requires entities selling digital assets to register with the GFSC as Virtual Asset Service Providers (VASPs).
*   **Financial Services (Core Principles and Consumer Duty) Regulations 2024:** Introduced in May 2024 to enhance retail customer outcomes for financial services firms, including those in the DLT sector.

Considerations

Notes

Detailed Content

Detailed Explanation

Gibraltar permits retail trading of cryptocurrencies under a comprehensive regulatory framework overseen by the Gibraltar Financial Services Commission (GFSC). The cornerstone of this framework is the Financial Services (Distributed Ledger Technology) Regulations 2017, which took effect on January 1, 2018. These regulations mandate that any firm conducting business in or from Gibraltar and utilizing distributed ledger technology (DLT) for storing or transmitting value belonging to others—including cryptocurrency exchanges and wallet providers—must be authorized by the GFSC as a DLT Provider. This licensing regime is principles-based and outcomes-focused. The GFSC's regulatory objectives prioritize market confidence, systemic risk reduction, consumer protection, the reputation of Gibraltar, and the reduction of financial crime.

A significant emphasis is placed on Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), and Counter-Proliferation Financing (CPF) compliance. Businesses in the crypto space must comply with the Proceeds of Crime Act 2015 (POCA) and its subsidiary legislation, including conducting customer due diligence (CDD), monitoring transactions, and reporting suspicious activities. The GFSC provides detailed guidance for DLT providers on AML/CFT/CPF expectations. Furthermore, Gibraltar has implemented the FATF's 'travel rule' through the Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021, requiring the collection and exchange of information for virtual asset transfers above a certain threshold.

Entities involved in selling digital assets, such as through initial token offerings (ITOs) or over-the-counter (OTC) desks, are required to register with the GFSC as Virtual Asset Service Providers (VASPs) under the Proceeds of Crime Act 2015 (Relevant Financial Business) (Registration) Regulations 2021. This registration also focuses on AML/CFT/CPF compliance. Although the regulations primarily target businesses providing crypto-related services, they indirectly govern and enable retail trading by ensuring that individuals transact through licensed and supervised entities that uphold high standards of consumer protection and financial crime prevention. There are no specific laws prohibiting individuals from buying, selling, or holding cryptocurrencies for their own account; the regulatory focus is on intermediaries and market infrastructure.

Gibraltar continuously evolves its regulatory landscape. In May 2024, the Financial Services (Core Principles and Consumer Duty) Regulations 2024 were introduced to enhance retail customer outcomes for financial services firms, including those in the DLT sector. More recently, in May 2025, Gibraltar announced its intention to establish a regulatory framework for the clearing and settlement of cryptocurrency derivatives, aiming to improve transparency and reduce operational risks in this segment of the market. The jurisdiction is also actively working on incorporating crypto assets into tax transparency frameworks, aligning with international efforts like the Crypto-Asset Reporting Framework (CARF). Exchanges under CARF are envisaged to commence in 2027 or 2028. The new framework for crypto derivatives is being developed in collaboration with the GFSC, government authorities, and crypto exchange Bullish.

Bullet Points

## Gibraltar: Retail Trading of Cryptocurrencies - Regulatory Analysis (2025-06-26)

**I. Overall Regulatory Status:**

*   **Allowed-Regulated:** Retail trading of cryptocurrencies is permitted but subject to comprehensive regulation.
*   No specific laws prohibit individuals from buying, selling, or holding cryptocurrencies.
*   Focus is on regulating intermediaries and market infrastructure.

**II. Key Regulatory Bodies:**

*   **Gibraltar Financial Services Commission (GFSC):**
    *   Primary regulator overseeing the crypto regulatory framework.
    *   Authorizes and supervises DLT Providers and VASPs.
    *   Promotes market confidence, reduces systemic risk, protects consumers, safeguards Gibraltar's reputation, and reduces financial crime.

**III. Important Legislation and Regulations:**

*   **Financial Services (Distributed Ledger Technology) Regulations 2017 (DLT Regulations):**
    *   Foundation of Gibraltar's crypto regulatory environment.
    *   Requires authorization from the GFSC for firms using DLT for storing or transmitting value belonging to others.
    *   Principles-based and outcomes-focused.
*   **Proceeds of Crime Act 2015 (POCA) and subsidiary legislation:**
    *   Focuses on Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), and Counter-Proliferation Financing (CPF) compliance.
    *   Includes requirements for customer due diligence (CDD), transaction monitoring, and reporting suspicious activities.
*   **Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021 (Travel Rule):**
    *   Implements the FATF's "travel rule."
    *   Mandates collection and exchange of information for virtual asset transfers above a certain threshold.
*   **Proceeds of Crime Act 2015 (Relevant Financial Business) (Registration) Regulations 2021:**
    *   Requires entities involved in selling digital assets (ITOs, OTC desks) to register with the GFSC as Virtual Asset Service Providers (VASPs).
    *   Focuses on AML/CFT/CPF compliance.
*   **Financial Services Act 2019:**
    *   Primary legislation regulating cryptocurrency companies in Gibraltar.
    *   Requires cryptocurrency companies to obtain a license from the GFSC to operate in Gibraltar.
*   **Financial Services (Core Principles and Consumer Duty) Regulations 2024:**
    *   Enhances retail customer outcomes for financial services firms, including those in the DLT sector.

**IV. Requirements for Compliance:**

*   **DLT Provider License (for relevant businesses):** Authorization from GFSC required for firms using DLT for storing or transmitting value belonging to others.
*   **VASP Registration (for entities selling digital assets):** Registration with GFSC required for entities involved in selling digital assets.
*   **AML/CFT/CPF Compliance:** Adherence to POCA 2015 and subsidiary legislation.
    *   Customer Due Diligence (CDD)
    *   Transaction Monitoring
    *   Suspicious Activity Reporting (SAR)
*   **Travel Rule Compliance:** Collection and exchange of information for virtual asset transfers above a certain threshold.

**V. Notable Restrictions or Limitations:**

*   While retail trading is permitted, individuals must transact through licensed and supervised entities.
*   The regulatory framework primarily targets businesses providing crypto-related services.

**VI. Recent Developments or Changes:**

*   **May 2024:** Introduction of the Financial Services (Core Principles and Consumer Duty) Regulations 2024 to enhance retail customer outcomes.
*   **May 2025:** Announcement of intention to establish a regulatory framework for the clearing and settlement of cryptocurrency derivatives.
*   **Ongoing:** Actively working on incorporating crypto assets into tax transparency frameworks (CARF).

Full Analysis Report

Complete markdown report for this analysis

## Retail_Trading_Status: Gibraltar

**Date:** 2025-06-26

**Status:** Allowed-Regulated

**Narrative Explanation:**

Gibraltar has established itself as a pioneering jurisdiction in the regulation of cryptocurrencies and Distributed Ledger Technology (DLT). Retail trading of cryptocurrencies by individual citizens and residents is legally permitted but is subject to a comprehensive regulatory framework. This framework is primarily overseen by the Gibraltar Financial Services Commission (GFSC).

The foundation of Gibraltar's crypto regulatory environment is the Financial Services (Distributed Ledger Technology) Regulations 2017 (the "DLT Regulations"), which came into effect on January 1, 2018. These regulations require any firm carrying on business, in or from Gibraltar, using DLT for storing or transmitting value belonging to others (which includes cryptocurrency exchanges and wallet providers) to be authorized by the GFSC as a DLT Provider. This licensing regime is principles-based and outcomes-focused, designed to be flexible and adaptive to the rapidly evolving nature of the technology. The GFSC's regulatory objectives include promoting market confidence, reducing systemic risk, protecting consumers and the reputation of Gibraltar, and reducing financial crime.

A key aspect of this regulatory framework is the strong emphasis on Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), and Counter-Proliferation Financing (CPF) compliance. Firms operating in the crypto space must adhere to the Proceeds of Crime Act 2015 (POCA) and its subsidiary legislation, including conducting customer due diligence (CDD), monitoring transactions, and reporting suspicious activities. The GFSC has issued detailed guidance for DLT providers on AML/CFT/CPF expectations. Furthermore, Gibraltar has implemented the FATF's "travel rule" through the Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021, which mandates the collection and exchange of information for virtual asset transfers above a certain threshold.

In addition to the DLT licensing framework for service providers, entities involved in selling digital assets, such as through initial token offerings (ITOs) or over-the-counter (OTC) desks, are required to register with the GFSC as Virtual Asset Service Providers (VASPs) under the Proceeds of Crime Act 2015 (Relevant Financial Business) (Registration) Regulations 2021. This registration also focuses on AML/CFT/CPF compliance.

While the regulations primarily target businesses providing crypto-related services, these comprehensive rules indirectly govern and enable retail trading by ensuring that individuals transact through licensed and supervised entities that uphold high standards of consumer protection and financial crime prevention. There are no specific laws prohibiting individuals from buying, selling, or holding cryptocurrencies for their own account. The focus is on regulating the intermediaries and the market infrastructure.

Gibraltar continues to evolve its regulatory landscape. In May 2024, the Financial Services (Core Principles and Consumer Duty) Regulations 2024 were introduced to enhance retail customer outcomes for financial services firms, including those in the DLT sector. More recently, in May 2025, Gibraltar announced its intention to establish a regulatory framework for the clearing and settlement of cryptocurrency derivatives, aiming to improve transparency and reduce operational risks in this segment of the market. The jurisdiction is also actively working on incorporating crypto assets into tax transparency frameworks, aligning with international efforts like the Crypto-Asset Reporting Framework (CARF).

**Relevant Text Excerpts and Sources:**

*   **CMS Expert Guide to Crypto Regulation Gibraltar:** "Since the 1st January 2018, any firm carrying out by way of business, in or from within Gibraltar, the use of distributed ledger technology (DLT) for storing or transmitting value belonging to other, needs to be authorised by the GFSC as a DLT provider."
*   **CMS Expert Guide to Crypto Regulation Gibraltar:** "For token sales (which generally fall outside of the DLT licensing framework) Gibraltar has a robust VASP registration system in place which connects project principles directly with the regulator to ensure a high standard of AML and KYC checks."
*   **Global Legal Insights - Blockchain & Cryptocurrency Laws and Regulations 2025 – Gibraltar:** "Gibraltar has a positive and welcoming attitude towards cryptocurrencies and blockchain technology. Gibraltar has been proactive in creating a favourable regulatory environment for crypto-related businesses. This is illustrated by the enactment of the Financial Services (Distributed Ledger Technology) Regulations (“DLT Regs”). Gibraltar became the first jurisdiction to provide a clear and comprehensive regulatory framework for blockchain and cryptocurrency businesses."
*   **Global Legal Insights - Blockchain & Cryptocurrency Laws and Regulations 2025 – Gibraltar:** "The Gibraltar Financial Services Commission (“GFSC”) regulates distributed ledger technology providers (“DLT Firms”), which include cryptocurrency exchanges and wallet providers, among others. Firms operating within this space are also required to comply with local anti-money laundering (“AML”), counter-terrorist financing (“CFT”) and counter-proliferation financing (“CPF”) rules and regulations contained within the Proceeds of Crime Act 2015 (“POCA”) and its subsidiary legislation."
*   **How to get a Crypto license (DLT license) in Gibraltar - Gofaizen & Sherle:** "Cryptocurrency is legal in Gibraltar. Gibraltar has implemented a regulatory framework for cryptocurrency businesses requiring a license from the Gibraltar Financial Services Authority."
*   **How to get a Crypto license (DLT license) in Gibraltar - Gofaizen & Sherle:** "The Financial Services Act passed in 2019, is the primary legislation regulating cryptocurrency companies in Gibraltar. Under the Financial Services Act, cryptocurrency companies must obtain a license from the GFSC to operate in Gibraltar."
*   **Gibraltar Finance - The Distributed Ledger Technology Regulatory Framework (DLTRF):** "The Distributed Ledger Technology (DLT) Regulatory Framework in Gibraltar, launched in January 2018, is one of the first pieces of legislation worldwide that specifically caters to DLT. It aims to establish an efficient and secure regulatory environment for companies utilizing DLT for value transmission or storage on behalf of others."
*   **GFSC Guidance Note - Scope of the DLT Framework:** "Therefore, any firm carrying on by way of business, in or from Gibraltar, the use of distributed ledger technology ('DLT') for storing or transmitting value belonging to others, needs to be authorised by the GFSC as a DLT Provider."
*   **Notabene - Travel Rule Crypto in Gibraltar by the GFSC:** "Yes. Gibraltar adopted a proactive and progressive approach to regulating the crypto industry by putting forward the Distributed Ledger Technology Framework (DLT Framework) as early as 2018. This framework regulates firms carrying out by way of business, in or from Gibraltar, the use of DLT for storing or transmitting value belonging to others."
*   **Coincub - Best Crypto Exchange Gibraltar:** "Gibraltar has generally been open to Bitcoin from the beginning of its rise as the foremost cryptocurrency... you're likely to find little difficulty trading Bitcoin in Gibraltar..."
*   **HM Government of Gibraltar - Gibraltar Strengthens Global Tax Transparency Commitment and Crypto-Asset Regulation (Jan 2025):** "Gibraltar is among the 61 jurisdictions committed to extending the automatic exchange of tax information to crypto-assets, a vital move in addressing the evolving challenges of the digital economy. Exchanges under CARF are envisaged to commence in 2027 or 2028."
*   **ThePaypers - Gibraltar develops rules for crypto derivatives clearing (May 2025):** "The new framework has been developed through collaboration between the Gibraltar Financial Services Commission (GFSC), government authorities, and crypto exchange Bullish. The initiative will allow the establishment of recognised clearing houses responsible for handling the finalisation of derivative trades involving virtual assets."

**Direct URL Links to Sources:**

*   [https://www.gfsc.gi/](https://www.gfsc.gi/) (Gibraltar Financial Services Commission official website - primary source for regulatory information, although specific documents cited might be deeper within the site or linked through secondary sources)
*   [https://www.gibraltarlaws.gov.gi/](https://www.gibraltarlaws.gov.gi/) (Official website for Gibraltar's laws - primary source for legislative texts)
*   [https://cms.law/en/int/expert-guides/cms-expert-guide-to-crypto-regulation/gibraltar](https://cms.law/en/int/expert-guides/cms-expert-guide-to-crypto-regulation/gibraltar) (Source)
*   [https://www.globallegalinsights.com/practice-areas/blockchain-laws-and-regulations/gibraltar](https://www.globallegalinsights.com/practice-areas/blockchain-laws-and-regulations/gibraltar) (Source)
*   [https://gofaizen-sherle.com/crypto-license-in-gibraltar](https://gofaizen-sherle.com/crypto-license-in-gibraltar) (Source)
*   [https://www.hassans.gi/publications/gibraltars-regulatory-framework-for-distributed-ledger-technology-and-its-proposals-for-token-sale-regulations/](https://www.hassans.gi/publications/gibraltars-regulatory-framework-for-distributed-ledger-technology-and-its-proposals-for-token-sale-regulations/) (Source - Example of a legal firm's analysis, similar content found in other legal/consulting firm publications)
*   [https://www.gibraltarfinance.com/financial-services/distributed-ledger-technology](https://www.gibraltarfinance.com/financial-services/distributed-ledger-technology) (Source)
*   [https://www.gfsc.gi/sites/default/files/2023-03/Scope%20of%20the%20DLT%20Framework.pdf](https://www.gfsc.gi/sites/default/files/2023-03/Scope%20of%20the%20DLT%20Framework.pdf) (Source - Specific GFSC Guidance Note)
*   [https://www.triay.com/publications/gibraltar-introduces-a-regulatory-framework-for-distributed-ledger-technology](https://www.triay.com/publications/gibraltar-introduces-a-regulatory-framework-for-distributed-ledger-technology) (Source - Example of a legal firm's analysis)
*   [https://www.charltonslaw.com/an-overview-of-the-regulation-of-virtual-assets-in-gibraltar/](https://www.charltonslaw.com/an-overview-of-the-regulation-of-virtual-assets-in-gibraltar/) (Source)
*   [https://www.notabene.id/crypto-regulation-gibraltar-travel-rule](https://www.notabene.id/crypto-regulation-gibraltar-travel-rule) (Source)
*   [https://thepaypers.com/cryptocurrencies/gibraltar-develops-rules-for-crypto-derivatives-clearing--1268685](https://thepaypers.com/cryptocurrencies/gibraltar-develops-rules-for-crypto-derivatives-clearing--1268685) (Source)
*   [https://coincub.com/country/gibraltar-crypto-guide/](https://coincub.com/country/gibraltar-crypto-guide/) (Source)
*   [https://www.ainvest.com/news/gibraltar-launches-worlds-first-crypto-derivatives-regulatory-framework-01hyg9ex9n7wz2r6m48vj4x7kz/](https://www.ainvest.com/news/gibraltar-launches-worlds-first-crypto-derivatives-regulatory-framework-01hyg9ex9n7wz2r6m48vj4x7kz/) (Source)
*   [https://www.gibraltar.gov.gi/newscentre/hmgog-press-releases-2025-15](https://www.gibraltar.gov.gi/newscentre/hmgog-press-releases-2025-15) (Source - Government Press Release)
*   [https://www.gibraltarfinance.com/news/why-digital-assets-need-regulations-now-more-than-ever-409](https://www.gibraltarfinance.com/news/why-digital-assets-need-regulations-now-more-than-ever-409) (Source)
*   [https://gbc.gi/news/gibraltar-continues-working-towards-incorporating-crypto-assets-within-tax-frameworks](https://gbc.gi/news/gibraltar-continues-working-towards-incorporating-crypto-assets-within-tax-frameworks) (Source)

Change Tracking

Change Justification

Explain why this analysis was changed or reconciled

Okay, as a specialized financial regulatory analyst, here's a detailed breakdown of the changes between the "Previous Analysis" (dated April 12, 2025) and the "New Analysis" (dated June 26, 2025) for Retail_Trading_Status in Gibraltar.

**Overall Summary of Changes:**

The `Retail_Trading_Status` remains `Allowed-Regulated`. Both reports confirm Gibraltar's pioneering role and the foundational DLT Regulatory Framework. However, the New Analysis incorporates more recent developments and announcements, particularly from late 2024 and the first half of 2025, reflecting Gibraltar's ongoing efforts to refine and expand its crypto-asset regulatory landscape. The New Analysis also provides slightly different nuances in its explanations and updates its source list to reflect more current information or different access points.

**Detailed Changes:**

**1. Current Status:**
*   **Previous:** `Allowed-Regulated`
*   **New:** `Allowed-Regulated`
*   **Change:** No change in the overall status.

**2. Narrative Explanation - Key Differences and Additions:**

*   **A. Introduction of New Regulatory Developments:**
    *   **Financial Services (Core Principles and Consumer Duty) Regulations 2024:**
        *   **Previous:** Not mentioned.
        *   **New:** "In May 2024, the Financial Services (Core Principles and Consumer Duty) Regulations 2024 were introduced to enhance retail customer outcomes for financial services firms, including those in the DLT sector."
        *   **Significance:** This is a significant update, highlighting a new piece of legislation aimed at strengthening consumer protection within the DLT space, directly relevant to retail trading.
    *   **Regulatory Framework for Clearing and Settlement of Cryptocurrency Derivatives:**
        *   **Previous:** Not mentioned.
        *   **New:** "More recently, in May 2025, Gibraltar announced its intention to establish a regulatory framework for the clearing and settlement of cryptocurrency derivatives, aiming to improve transparency and reduce operational risks in this segment of the market."
        *   **Significance:** Indicates proactive steps to regulate more complex crypto products, expanding the scope of oversight.
    *   **Crypto-Asset Reporting Framework (CARF):**
        *   **Previous:** Not mentioned.
        *   **New:** "The jurisdiction is also actively working on incorporating crypto assets into tax transparency frameworks, aligning with international efforts like the Crypto-Asset Reporting Framework (CARF)." (Supported by an excerpt dated Jan 2025).
        *   **Significance:** Shows alignment with international tax transparency initiatives, which will impact reporting requirements for crypto assets.

*   **B. Refinements and Clarifications in Existing Framework Description:**
    *   **DLT Regulations Naming:**
        *   **Previous:** "Financial Services (Distributed Ledger Technology Providers) Regulations 2017/2020 and now integrated within the Financial Services Act 2019 (FSA)."
        *   **New:** "Financial Services (Distributed Ledger Technology) Regulations 2017 (the "DLT Regulations")." (The Financial Services Act 2019 is mentioned later in an excerpt).
        *   **Significance:** A slight simplification in the primary naming in the narrative, though the underlying legislation is the same.
    *   **GFSC Regulatory Objectives:**
        *   **Previous:** Mentioned "consumer protection, market integrity, and the prevention of financial crime" as key objectives for DLT Providers.
        *   **New:** Expands on GFSC's objectives: "promoting market confidence, reducing systemic risk, protecting consumers and the reputation of Gibraltar, and reducing financial crime."
        *   **Significance:** Provides a broader view of the GFSC's mandate.
    *   **GFSC Guidance:**
        *   **Previous:** Implied through the principles-based approach.
        *   **New:** Explicitly states: "The GFSC has issued detailed guidance for DLT providers on AML/CFT/CPF expectations."
        *   **Significance:** Highlights the availability of specific guidance from the regulator.
    *   **VASP Registration Examples:**
        *   **Previous:** Mentioned "token issuers or OTC desks" for VASP registration.
        *   **New:** More specific: "entities involved in selling digital assets, such as through initial token offerings (ITOs) or over-the-counter (OTC) desks, are required to register..."
        *   **Significance:** Clearer examples of activities requiring VASP registration.

*   **C. Changes in Emphasis or Omissions in Narrative:**
    *   **Ten Core Principles:**
        *   **Previous:** "There are ten core principles that licensed DLT Providers must adhere to..."
        *   **New:** Mentions the framework is "principles-based and outcomes-focused" but does not specify the number of principles in the narrative.
        *   **Significance:** Minor de-emphasis on the specific number, though the principles-based nature remains.
    *   **FATF Travel Rule Threshold:**
        *   **Previous:** Explicitly mentioned "EUR 1,000" threshold in the narrative.
        *   **New:** States "above a certain threshold" in the narrative. The specific threshold is not mentioned in the new narrative but is implied by referencing the rule.
        *   **Significance:** Less specific in the narrative text itself.
    *   **GFSC Public Warnings:**
        *   **Previous:** "The GFSC actively supervises licensed and registered entities and issues public warnings regarding unauthorized firms..."
        *   **New:** This specific point about public warnings for unauthorized firms is not explicitly reiterated in the new narrative, though the GFSC's supervisory role is clear.
        *   **Significance:** A minor shift in emphasis; the function likely continues but isn't highlighted in the same way.

**3. Supporting Excerpts:**

*   **New Excerpts Added:**
    *   **HM Government of Gibraltar - Gibraltar Strengthens Global Tax Transparency Commitment and Crypto-Asset Regulation (Jan 2025):** Supports the CARF development.
    *   **ThePaypers - Gibraltar develops rules for crypto derivatives clearing (May 2025):** Supports the derivatives framework announcement.
    *   **Coincub - Best Crypto Exchange Gibraltar:** General statement on ease of trading Bitcoin.
*   **Excerpts Largely Carried Over (with potential minor wording/source attribution differences):**
    *   CMS Expert Guide (DLT licensing, VASP registration).
    *   Global Legal Insights (positive attitude, DLT Regs, GFSC regulation, AML/CFT/POCA).
    *   Gofaizen & Sherle (legality, DLT license, Financial Services Act 2019).
    *   Gibraltar Finance (DLT Framework).
    *   GFSC Guidance Note (Scope of DLT Framework).
    *   Notabene (Travel Rule implementation).
*   **Excerpts from Previous Analysis Not Directly Replicated or Replaced:**
    *   The specific excerpt about the "ten core principles" from Hassans Law Firm.
    *   The specific GFSC warning example (GFSC News, Mar 2023).
    *   Some excerpts might be covered by similar content from different sources in the new analysis.

**4. Source URLs:**

*   **New Sources/URLs Added in New Analysis:**
    *   Direct links to `gfsc.gi` and `gibraltarlaws.gov.gi` as primary sources.
    *   `gofaizen-sherle.com/crypto-license-in-gibraltar` (updated URL or more specific link).
    *   `hassans.gi/publications/...` (specific publication link).
    *   `triay.com/publications/...`
    *   `charltonslaw.com/...`
    *   `notabene.id/crypto-regulation-gibraltar-travel-rule` (updated or more specific link).
    *   `thepaypers.com/...` (for derivatives news).
    *   `coincub.com/...`
    *   `ainvest.com/...` (alternative source for derivatives news).
    *   `gibraltar.gov.gi/newscentre/...` (Gov press release for CARF).
    *   `gibraltarfinance.com/news/...` (general article on regulation).
    *   `gbc.gi/news/...` (news on CARF).
*   **Sources from Previous Analysis Not Explicitly Carried Over or Changed:**
    *   The previous report had a broader list of inferred links or search result-based links (e.g., [2], [4], [5], [6], [7], [9], [10], [12], [13], [15], [16], [17], [19], [21]). The new report uses more direct, specific URLs where possible and introduces new sources for recent developments. Some previous sources might be implicitly covered if the information is now cited from a different, more current, or more direct source. For example, information from "21 Analytics" or "Prifinance" might be covered by the more primary or comprehensive legal firm/regulatory links.

**Conclusion of Changes:**

The New Analysis provides a more current snapshot of Gibraltar's retail crypto trading status. While the fundamental allowance and regulatory approach (DLT licensing, VASP registration, AML/CFT focus) remain consistent, the key changes lie in the incorporation of:
1.  **The Financial Services (Core Principles and Consumer Duty) Regulations 2024.**
2.  **The planned regulatory framework for cryptocurrency derivatives clearing and settlement (May 2025).**
3.  **Gibraltar's commitment to the Crypto-Asset Reporting Framework (CARF) for tax transparency.**

These additions demonstrate Gibraltar's continuous evolution of its regulatory framework to address new market segments (derivatives), enhance consumer protection, and align with international standards (CARF). The narrative has been updated to reflect these, and the supporting evidence and sources have been refreshed accordingly.

Previous Status: Allowed-Regulated

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