Research
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Research
How Crypto Exchange Licensing in the Americas Actually Unlocks Banking Access and Scale
Contents
01
02
Key Takeaways for Crypto Exchange Operators
03
No Passport, But Real Momentum
04
Why Freedx Chose El Salvador First
05
What Actually Carries Over Between Licenses
06
What Operators Most Often Underestimate
07
Building for Credible Expansion
01
Licensing is no longer a checkbox for crypto exchanges expanding across the Americas. It is the foundation that determines whether banks will open rails, whether institutional partners will engage, and whether the next market entry takes months or years.
In a recent CoinGecko fireside chat, operators and advisors examined a critical question: Does the license you already hold actually help you win the next one? The panel featured:
Karim Emam, Chief Strategy Officer at Freedx
Mitzi Pichardo, Associate General Counsel at Bitso (formerly at Mexico’s Financial Intelligence Unit)
Felix, Head of Latin America and Associate Partner at Gofaizen & Sherle
Their answers were consistent: there is no formal passport across the Americas, but the right first license creates reusable infrastructure, supervisory credibility, and a clearer path to banking relationships.
02
Key Takeaways for Crypto Exchange Operators
A license in one Americas jurisdiction does not legally authorize operations in another (unlike EU MiCA passporting).
Existing licenses still accelerate future applications by transferring operational muscle, audit trails, and regulator confidence.
Sequencing matters: starting with a reputable, well-executed license reduces long-term friction with banks and subsequent regulators.
Technology stack, expert team, and clean documentation are the three pillars that travel best across borders.
Independent, verifiable market data and pricing have moved from “nice-to-have” to regulatory expectation.
Customer problem and product-market fit should drive licensing strategy — not license collection for its own sake.
03
No Passport, But Real Momentum
Unlike Europe’s MiCA regime, a crypto license in Mexico, El Salvador, or Brazil does not automatically open the rest of the region. Felix was direct:
“From a technical perspective, we’re not in a place… where there is a formal passporting scheme… Nevertheless, from a practical perspective, it does help… You will already have the infrastructure… [and] it’s always a green flag for a company… to already showcase that they have gone through a licensing process.”
Mitzi Pichardo of Bitso echoed the distinction between legal rules and operational reality:
“The legal requirements rarely transfer directly… But what does transfer is the operational muscle and experience from previous processes — anti-money laundering and travel-rule infrastructure, board-level governance, risk policies, [and] the ability to produce a clean audit trail. Once those capabilities exist, standing it up for the next regulators is faster… because the internal machinery already does.”
A clean supervisory history also changes the conversation with new regulators — from “prove you are not a risk” to “show how this compares to the framework you already operate under.”
04
Why Freedx Chose El Salvador First
Freedx’s (https://freedx.com) founding team is UK- and Dubai-based. The conventional path would have been a license closer to home. Instead, the company secured its Digital Asset Service Provider (DASP) and Bitcoin Service Provider licenses in El Salvador before the product was fully built.
Karim Emam explained the strategic logic:
“We knew that we needed a reputable license that we can get… Looking at the Latin region, even though Mexico is a much more attractive market… [it] suffered from the same issues as the UK… El Salvador… we had imagined that they would somewhat be more so pioneers within the rest of the LatAm space… Our El Salvador license… provides us that initial base where we can continue building our long-term licensing strategy over top of and gives the confidence to our partners.”
The license was never primarily about serving El Salvador as a core commercial market. It was about establishing credible regulatory standing that banks, partners, and future regulators could trust while the team executed its broader roadmap.
05
What Actually Carries Over Between Licenses
When operators apply for a subsequent license, three elements travel most effectively:
Technological infrastructure already aligned with KYC, travel-rule, transaction monitoring, custody, and pricing requirements.
An expert team capable of implementing regulated services (compliance, cybersecurity, finance, operations).
Coherent legal and policy documentation that demonstrates both capability and governance under active supervision.
These pillars are not identical across jurisdictions, but once stress-tested by one reputable regulator they significantly reduce the time, cost, and uncertainty of the next application.
Independent pricing data has also become a hard requirement in many processes. Mitzi noted that Bitso publishes live prices via an open API so regulators, auditors, and third parties can reconstruct any price independently. Karim added that while banks focus primarily on source-of-funds and monitoring for fiat rails, regulators increasingly examine whether exchanges offer customers fair, third-party-referenced prices in a fragmented market.
06
What Operators Most Often Underestimate
Mitzi Pichardo highlighted three frequent gaps:
Believing you can understand a market from the outside. Real insight comes from industry associations, regulator roundtables, and relationships built before you need anything.
Under-budgeting the post-approval period while the regulator is still learning how much to rely on you.
Assuming compliance programs are fully portable. Local risk priorities, typologies, and reporting expectations differ.
Felix cautioned against treating licensing as a collection exercise:
“This is not just a game of collecting licenses all over… You need to be smart about what you want to do for your company… What’s your target? What type of services do you want to focus on?”
Karim Emam stressed prioritization for new exchanges:
“There’s too many operators… that start thinking, ‘I want to launch an exchange. I need a license. I have 300 tokens’… They’re not thinking about the customer first… Make sure that you’re offering a strong product… [and] consider… do I have the resources and funds to be able to sustain having this licensing overhead.”
On the practical choice between securing an own license versus entering via local partnership, both Karim and Mitzi favored partnerships as a lower-cost first step when they unlock the necessary rails, while retaining the longer-term goal of owning the full regulatory and control perimeter.
07
Building for Credible Expansion
A well-executed first license in the Americas does not magically open every other market. It does create the operational foundation, supervisory track record, and external credibility that banks and subsequent regulators now demand.
Exchanges that sequence markets deliberately, invest early in robust compliance and verifiable data infrastructure, and treat licensing as an extension of their commercial strategy — rather than a parallel collection project — position themselves to scale more efficiently across the region.