Banks and digital assets: what 40 licensing files reveal

Demonstration article. The banks, people, files and figures cited are fictional, including the approval times attributed to each country.

• Across forty bank licensing files, the median review time ranges from 212 to 452 days depending on the country.
• Fourteen banks filed in a country where they do little business, to benefit from a faster review.
• No public indicator currently allows review times to be compared from one authority to another.

When the management of Banque Orsel, a mid-sized bank present in three European countries, decided in 2024 to offer crypto-asset custody to its institutional clients, the first meeting was about neither technology nor clients. It was about one question: in which country should the application be filed?

“We had teams in three jurisdictions. The choice was not made on the quality of supervision or proximity to clients, but on the likely timeline,” recalls a member of the executive committee at the time. The bank eventually filed in Luxembourg. It obtained its licence in seven months.

How we reconstructed the files

To measure these gaps, we cross-checked three sources: filing dates provided by the banks themselves or their advisers, decision dates in public registers, and accounts from eleven lawyers and compliance officers who worked on these applications. Forty applications could be reconstructed from start to finish, in six countries.