※1: According to the Financial Services Agency’s guidelines, a crypto asset exchange business license is required. If the business operator is in a position to proactively transfer the user’s crypto assets, such as when it possesses a private key that can be used to transfer the user’s assets, it falls under custody and storage for others.（Crypto Asset Administrative Guideline: Ⅰ-1-2-2③)

※2: It is only required when there is no lock-up and no specified termination date ( Referred  to Licenses required for lending＆staking).

※3: Since the investment target of the investment management business is limited to securities or derivative transactions, a fund that invests only in crypto assets, excluding derivatives, is exempt from the requirement for an investment management business license. (FIEA: Article 2(8)(xii)・(xiv)・(xv)). However, many current crypto asset funds require an investment management business license because they invest in securities and crypto assets at the same time.Furthermore, in cases such as staking, where assets in custody are managed in assets other than crypto assets such as crypto asset derivatives and securities to generate yields, registration as an investment management business is required.

※4: Depending on the scheme, separate licenses for Electronic Payment Service Provider (The Banking Act) and Electronic Payment Instruments Transaction Service Provider (Payment Service Act) are required when giving stablecoins as rewards for lending or staking to participants. (Referred to Trading with Stablecoins).

※5: A crypto asset exchange business license is required to exchange crypto assets and fiat currency.

For example:

1. Offering stores a system that allows intermediaries to accept payments in crypto assets, 
2. When the purchaser sends the cryptocurrency in accordance with the store’s instructions, the procedure for sending the cryptocurrency to the intermediary is carried out. 
3. By confirming the transmission procedure, the intermediary completes the purchaser’s payment settlement without waiting for the cryptocurrency to move.

※6: Because investment management activities typically include crypto asset trading, the relevant asset management company must register as a crypto asset exchange business.Even in this case, registration as an exchange business is not required if the investment assets of a fund organized overseas are managed by an overseas management company that receives discretionary investment management and the management operations are conducted overseas, even if Japanese investors participate in the fund. (Referred to Public Comment No. 228 published by the Financial Services Agency on April 3, 2020).