Regulatory status

Why this page exists

Every platform serving crypto customers in Kuwait does so cross-border on a foreign licence. We reviewed the five largest and not one explains what that means for the customer. You are entitled to know before you send money, not afterwards.

A licence is also the easiest thing on a website to imply and the hardest thing for a reader to check. So this page states exactly what we hold, exactly what it permits, exactly what we do with it, and exactly how to confirm all three without taking our word for any of it.

Who you contract with

Kafil W.L.L., a company registered in the Kingdom of Bahrain. Your contract is with that company and no other.

The licence we hold

Kafil W.L.L. holds a Category 2 Crypto-Asset Services Company Licence issued by the Central Bank of Bahrain, granted on 19 February 2026 under Volume 6 (Capital Markets) of the CBB Rulebook, Crypto-Asset Module (CRA).

Category 2 is not the largest licence in the Bahraini regime, and we chose it deliberately. The four categories run:

Category 2 is the lowest category that carries crypto-asset custody, which is the permission an escrow service actually needs. Category 1 stops short of it. Categories 3 and 4 would add principal trading and exchange operation, permissions we do not want, would not use, and would then have to be supervised against. A firm holding more permissions than it uses is not more trustworthy for it.

For context, Rain Management W.L.L. was licensed by the CBB in July 2019 and CoinMENA in January 2021, both at Category 3.

What the licence permits, and what we actually do

This distinction matters more than the licence itself, and almost nobody publishes it.

The register will show four permitted activities against our name:

• Crypto-asset custody: this is what we do
• Agency trading in accepted crypto-assets: permitted, not carried on
• Portfolio management: permitted, not carried on
• Investment advice: permitted, not carried on

We hold funds in escrow. We do not trade for you, manage anything for you, or advise you on what to buy. If anyone at Kafil ever offers you any of the latter three, they are exceeding what this company does and you should tell our Compliance Officer.

How to verify it, and why there is no number

The CBB does not issue per-licence reference numbers. This is a genuine quirk of the Bahraini regime and it is worth understanding, because it cuts both ways.

Dubai's VARA issues numbers in the form VL/25/10/001. ADGM issues a six-digit financial services permission number. The CBB issues neither. There is therefore no "CBB licence number" for us to display, and any operator showing you one has invented it. That is a useful test you can apply to our competitors as well as to us.

Verification is by entity name. Search Kafil W.L.L. in the CBB Licensing Directory. The directory returns the licensee record, the permitted activities attached to it, the approved persons the CBB has signed off in controlled functions, and the controllers of the company. That is materially more information than a number would give you, and it comes from the regulator rather than from us.

The CBB notes that register content is supplied by licensees. If anything there does not match what this page says, the register is the record that matters, and we would like to know.

What being licensed obliges us to do

Not a badge. A set of continuing conditions, the ones that affect you most directly being:

• Minimum capital of BHD 100,000, paid up and deposited with a local Bahraini retail bank, maintained for the life of the licence. The CBB may require more if it considers it necessary for the financial integrity of our operations.
• Liquid assets covering at least three months of operating expenses, so that an orderly wind-down is funded rather than hypothetical.
• Client asset segregation. Client crypto-assets must be held separately from our own, under the client-asset rules the CRA Module imports from the CBB's Market Intermediaries and Representatives module. Client assets are not ours and are ring-fenced from claims by our creditors.
• Approved persons. Our controlled functions (the Senior Executive Officer, the Compliance Officer and MLRO) are individually vetted and approved by the CBB, not merely appointed by us.
• Periodic reporting and audit to the CBB, and an AML programme built to the Bahraini framework implementing the FATF standard.

Why Bahrain and not Kuwait

Because Kuwait issues no licence for this activity to anyone.

CMA Circular No. (10) of 2023, issued on 17 July 2023 by the Capital Markets Authority together with the Central Bank of Kuwait, the Ministry of Commerce and Industry and the Insurance Regulatory Unit, imposes:

• an absolute prohibition on virtual assets as a payment instrument;
• a prohibition on dealing in virtual assets as a means of investment;
• a prohibition on granting any person in Kuwait a licence to provide virtual asset services as a commercial business;
• a prohibition on mining;
• a prohibition on regulated entities providing related services.

Securities regulated by the Central Bank of Kuwait, and other instruments regulated by the CMA, are carved out. Virtual assets are not.

There is therefore no Kuwaiti licence we are missing. There is no Kuwaiti licence.

The position hardened rather than softened. In April 2025 the Ministry of Interior declared crypto mining illegal nationwide. A draft virtual assets framework consulted on in 2023 was never adopted. And Kuwait was added to the FATF list of jurisdictions under increased monitoring on 13 February 2026, remaining listed at the June 2026 plenary, which points towards more banking friction, not liberalisation.

What the Kuwaiti circular actually says about dealing abroad

This is the part that gets reported as "Kuwait banned crypto" and is more precise than that.

Circular No. (10) of 2023 is addressed to financial institutions and designated non-financial businesses and professions in Kuwait. It is not addressed to you as an individual, and it is not addressed to us. We are neither.

The circular expressly contemplates virtual-asset transactions "executed outside the State of Kuwait with the knowledge of clients", and the obligation it attaches to those is a continuing one: to constantly inform clients about the risks associated with dealing in virtual assets, particularly that they lack legal status and are not issued or endorsed by any government.

So the circular's own treatment of cross-border dealing is a disclosure duty, not a prohibition on the client. That duty binds Kuwaiti financial institutions rather than us. We apply it to ourselves anyway. It is the standard the local regulator considers appropriate for exactly this situation, and adopting it voluntarily costs us nothing but a clearly-written page. Our Risk Disclosure is how we discharge it.

Breach of the circular attracts the measures in Article 15 of Law No. 106 of 2013 on Anti-Money Laundering and Combating the Financing of Terrorism, alongside whatever each regulator imposes.

What this means for you

Your contract is with a Bahraini company and Bahraini law governs it. Not Kuwaiti law. If you are in Kuwait, you are dealing with us cross-border, and you should read the two sections above before deciding that is acceptable to you.

Your recourse runs through Bahrain. Internal appeal first, then expert determination, the Bahrain Chamber for Dispute Resolution or SIAC depending on the amount, set out in full on our Complaints & Disputes page. Realistically: for a dispute of a few thousand dollars the remedy that will actually be used is our internal process, and you should weigh that before committing to a large deal with a counterparty you do not know.

You can complain to our regulator. If we fail to resolve a complaint, the CBB supervises us and operates its own consumer complaints route. That is a real escalation that did not exist before we were licensed.

The CBB supervises us; it does not underwrite us. Supervision means our capital, our controls, our approved persons and our conduct are subject to a regulator's scrutiny. It does not mean anyone repays you if a deal goes wrong. There is no deposit-guarantee or investor-compensation scheme covering funds held in escrow. See Risk Disclosure.

If we failed, your funds are not part of the wreckage. Two things protect them, and they are independent of each other:

1. As a CBB licensee we sit outside the ordinary Reorganisation and Bankruptcy Law No. 22 of 2018. Insolvency of a licensee is dealt with under the Central Bank of Bahrain and Financial Institutions Law of 2006, with the CBB involved. Client assets are segregated from ours under the CRA Module and are not available to our creditors.
2. More directly: we hold one key of three. You and your counterparty hold the other two. If we lost our licence tomorrow, went insolvent, or simply stopped answering the phone, the two of you could still move the funds without us.

The second is the one we would rely on, and it is why we built the service that way. The first is a legal argument that would have to be run. The second is arithmetic that is already true.

We cannot act for everyone. See Restricted Jurisdictions.

What we do not say

We do not describe ourselves as licensed or regulated in Kuwait, because no such licence exists for anyone.

We do not describe our Bahraini licence as covering activities it does not, or as covering activities we do not perform.

We do not display a licence number, because the CBB does not issue one.

We do not imply that a Kuwaiti framework is imminent. The 2023 draft was never adopted and we have no basis to suggest otherwise.

We do not use a foreign licence to imply Kuwaiti oversight that is not there.

We do not use the words "guaranteed", "risk-free" or "insured" about this service. Misleading commercial claims carry penalties of up to KWD 20,000 and two years' imprisonment under Kuwait's Consumer Protection Law No. 39 of 2014. Beyond the legal exposure, that vocabulary belongs to the operators this market has been badly served by.

If you see any of those claims from anyone operating here, treat them with suspicion.

Not legal advice

Nothing on this page is legal advice to you. If the legal position of digital assets in Kuwait matters to your circumstances, take your own advice.