Damex Gibraltar: Regulatory Status and Corporate Structure

Damex in Gibraltar: examining the group’s regulatory status and corporate structure.

Damex is a financial technology company headquartered in Gibraltar, with a focus on digital assets and related payment solutions. Its operations place it within a very particular area of financial services supervision, one that deals with firms holding, transferring or otherwise managing value through blockchain or comparable distributed ledger technology (DLT).

Gibraltar has spent years presenting itself as an international hub for businesses in this space, introducing a regulatory framework that sits alongside its established financial services legislation. This positioning is intended to balance innovation with regulatory oversight, offering companies like Damex a legal environment in which to operate while reassuring counterparties that standards are monitored by a statutory authority.

Within this framework, Damex has sought to bridge elements of conventional finance and newer digital asset services. On one side of its offering are products associated with traditional payment infrastructure, such as fiat accounts, international transfers and operational banking functions. On the other side are solutions designed to enable clients to hold, manage and transfer digital assets securely, subject to applicable regulatory requirements. In its earlier years, the company opened these services to both retail and corporate clients, although it has since shifted towards a business-to-business focus. This means that Damex is supervised for a range of regulatory obligations, covering anti-money laundering requirements, operational resilience, governance, financial stability and the protection of client assets.

A number of these details can be independently confirmed through sources in the public domain. Company disclaimers, contractual documents and entries on Gibraltar’s corporate registry provide insights into licensing and incorporation. Yet, as is the case with many firms in this sector, there are also areas where less information is publicly disclosed.

The composition of governance structures, the number of employees located in Gibraltar or the precise distribution of compliance responsibilities across jurisdictions are not set out in registry filings. Observers are therefore left to interpret the company’s standing from the information that is verifiable.

This article is based solely on official and publicly accessible material. It references corporate filings, press releases from the Government of Gibraltar, registers maintained by the Gibraltar Financial Services Commission (GFSC) and legal agreements issued by Damex itself. It also considers the obligations imposed by Gibraltar’s licensing framework for DLT providers, setting out where expectations are defined by law and where operational information is only known to the firm and its regulator.

Gibraltar’s licensing framework

Gibraltar introduced its Distributed Ledger Technology regulatory regime at the beginning of 2018, making it one of the first jurisdictions to codify rules for the sector. The law applies to any entity carrying on business in or from Gibraltar that stores or transmits value on behalf of third parties using distributed ledger technology.

This is a broad definition, intended to capture not just cryptocurrencies but also other systems where transactions are recorded, validated and shared on a decentralised network. The legal term “DLT” is therefore wider than blockchain alone and includes permissioned as well as public networks.

Unlike heavily prescriptive systems in some other jurisdictions, Gibraltar adopted a principle- based approach. The legislation sets out ten high-level principles which every licensed firm must meet, covering corporate governance, operational risk, client disclosures, financial stability, data security and anti-money laundering.

Each principle is deliberately broad, leaving it to the firm to show how it complies in practice. The regulator, the GFSC, then supervises this compliance, reviewing whether the measures adopted by the business are sufficient in light of its particular model and activities.

A crucial feature of this framework is the requirement for “mind and management” to be located in Gibraltar. In effect, this means that strategic decision-making and operational direction must be undertaken by individuals physically based in the jurisdiction. The principle aims to avoid a situation where a company is legally incorporated in Gibraltar but effectively directed from abroad, ensuring accountability to local law.

To monitor this, the GFSC has powers to inspect licensed firms, request reports, demand documentary evidence and, if necessary, impose enforcement measures. The regime is intended to provide both flexibility and certainty, allowing different business models to function while ensuring the public can rely on an underlying standard of supervision.

Damex’s licensed entity

Independent records confirm that Damex operates through Digital Asset Management Limited, registered in Gibraltar under company number 116618. This company holds DLT Provider licence number 24738, issued by the GFSC. The entity trades under the names “Damex” and “Damex.io”, both of which appear across client agreements, marketing material and the GFSC’s own public register of authorised firms.

The Gibraltar Government itself acknowledged the company’s licensing milestone in a press release dated March 2019, identifying Damex as one of the early licensees under the DLT regime. According to that release, the process leading to approval had lasted approximately a year, reflecting the GFSC’s practice of carefully examining each applicant’s governance arrangements, risk management systems, financial resilience and technological capabilities.

Damex’s client contracts are consistent with this public record. Documents such as its OTC Client Agreement and Master Terms specify the company’s registration number, its official registered office at Suite 1, Burns House, 19 Town Range, Gibraltar and the choice of Gibraltar law as the governing legal system. By cross-referencing these sources, observers can be confident of the company’s licensed status.

What is not covered in these documents, are operational specifics such as how governance responsibilities are divided among directors, the number of employees working on compliance or whether oversight committees exist within the group. These matters remain private unless voluntarily disclosed.

Parent company and group structure

According to Damex’s website disclaimers, its ultimate parent entity is The Experience Holding Limited, incorporated in Gibraltar under company number 123183. The holding company lists the same registered office address as the operating subsidiary. Identifying the parent is important, as it clarifies where ownership and governance responsibilities ultimately lie. In corporate structures of this type, the holding company may provide strategic direction, control intellectual property, consolidate finances or act as the shareholder for operating subsidiaries.

Filings at Gibraltar Companies House are expected to confirm director appointments, shareholder information, changes in capital and other statutory details. Such documents can provide insight into whether ownership is concentrated or dispersed, whether there have been recent structural changes and whether directors hold overlapping responsibilities in other entities.

What they cannot provide, is a detailed picture of day-to-day management or the distribution of staff resources. This distinction matters, because while the ownership chain can be legally confirmed, operational matters often remain invisible outside regulatory filings.

Third-party payment arrangements

Damex’s own contractual documents make clear that Digital Asset Management Limited is registered as an agent or distributor of Modulr FS Limited, a UK-based Electronic Money Institution (EMI) authorised and supervised by the Financial Conduct Authority (FCA).

This arrangement enables Damex clients to access certain fiat services, including IBAN issuance, through Modulr’s systems.

For clients, this means that although they may interact directly with Damex in onboarding and communication, the regulatory responsibility for safeguarding fiat funds ultimately rests with Modulr. Under UK law, EMIs must segregate client money from their own funds, apply anti- money laundering measures and maintain compliance with strict operational and financial stability requirements. Damex’s role is therefore partly that of an introducer and manager of client relationships, while Modulr acts as the licensed custodian for fiat transactions.

Such arrangements are common in the fintech sector, where companies without their own EMI licence rely on partnerships to deliver certain services. They do create a layered contractual relationship and clients must be aware of which regulator has oversight at each stage.

In Damex’s case, the GFSC supervises the DLT element of its operations, while the FCA supervises Modulr’s EMI activities. The partnership illustrates the cross-border nature of modern financial services and the need for clarity about accountability.

Business transition after 2024

In October 2024, Damex announced the sale of its retail-facing division to Ziglu, a UK-based cryptocurrency banking application. The transaction, which was widely reported in established outlets including Sky News, the Gibraltar Chronicle and Tech.eu, was structured as an all-share deal. This meant that instead of receiving cash, Damex took an equity position in Ziglu.

The sale marked a significant strategic shift. Damex ceased offering direct services to retail customers and focused instead on B2B solutions. Ziglu took over the retail client base, integrating those accounts into its own systems. This pivot has regulatory implications.

Retail-facing operations typically involve large numbers of individual customers, requiring firms to implement systems for consumer protection, financial education and monitoring of many small-value transactions. By contrast, B2B services generally involve fewer clients with higher transaction values and more complex corporate structures.

For Damex, this change likely reduced the operational burden of managing thousands of small accounts but increased the need for in-depth due diligence on a smaller number of sophisticated clients. Regulators usually expect firms to adapt their compliance structures accordingly, ensuring that beneficial ownership verification, transaction monitoring and risk management remain proportionate to the business model.

The shift illustrates how strategic decisions can influence not only commercial focus but also the regulatory expectations applied to a licensed entity.

Areas not covered by public records

In June 2025, Malta Media submitted written questions to Damex seeking clarification on operational matters not visible from public records. These included the size of its compliance and AML teams, their location and how decision-making authority is allocated within Gibraltar. As of the time of writing, no reply has been received. The lack of response does not suggest any wrongdoing; rather, it reflects the reality that Gibraltar’s regulatory framework does not require firms to publish this information.

Without voluntary disclosure, observers are left with an incomplete picture. While the GFSC has access to the information it needs to supervise licensed firms, the general public, potential counterparties and clients must rely on statutory filings and contractual documents. These records confirm licensing and ownership but do not reveal operational details.

For those assessing the company’s resilience, governance culture or compliance readiness, this creates a distinction between what is verifiable in law and what remains internal.

Observations on transparency

The verifiable record confirms that Damex is a licensed DLT Provider supervised by the GFSC, operating through Digital Asset Management Limited and owned by The Experience Holding Limited. The firm’s partnership with Modulr FS Limited for fiat services is clear in its contractual disclosures and represents a well-established industry model.

The October 2024 divestment of its retail business to Ziglu is confirmed by multiple independent sources and reflects a conscious move toward institutional services.

What remains uncertain, are the company’s internal governance and staffing structures. Information about the number of compliance staff based in Gibraltar, the distribution of responsibilities under the Modulr arrangement or the exact oversight processes for client asset safeguarding are not publicly disclosed.

While this absence is not unusual, it means that assessments of Damex’s long-term stability must rely on what is filed in public registries and what is confirmed in contractual terms.

The absence of publicly available operational detail is consistent with regulatory practice in Gibraltar and should not be interpreted as evidence of any deficiency.

This article makes no allegation of wrongdoing and avoids drawing speculative conclusions. It relies exclusively on verifiable official records, company disclosures and reports from established media outlets. Its purpose is to present the facts as they can be confirmed, while noting the areas where voluntary transparency could assist stakeholders in understanding how Damex satisfies Gibraltar’s regulatory principles for DLT providers.

FAQs

What is Damex and where is it headquartered?
Damex is a fintech company focused on digital assets and payment solutions, headquartered in Gibraltar.

What regulatory framework governs Damex in Gibraltar?
Damex is regulated under Gibraltar’s Distributed Ledger Technology (DLT) regime and supervised by the GFSC.

Which legal entity operates Damex in Gibraltar?
Damex operates through Digital Asset Management Limited, holding DLT Provider licence number 24738.

Who owns Damex?
The ultimate parent company is The Experience Holding Limited, incorporated in Gibraltar.

What services did Damex provide before 2024?
Damex offered retail and corporate digital asset services, including fiat accounts, international transfers, and DLT solutions.

What change occurred in Damex’s business model in 2024?
Damex sold its retail-facing division to Ziglu and shifted to B2B digital asset services.

How does Damex handle fiat transactions for clients?
Damex partners with Modulr FS Limited, a UK EMI, which safeguards fiat funds and complies with FCA regulations.

What areas of Damex operations are not publicly disclosed?
Operational governance, staff numbers, and internal compliance distribution remain private unless voluntarily disclosed.

What does “mind and management” in Gibraltar regulation mean?
It requires strategic and operational decision-making to be conducted by individuals physically located in Gibraltar.

Where can one verify Damex’s regulatory status?
Through the GFSC register of licensed DLT providers and official company filings in Gibraltar Companies House.

Full source list

Gibraltar Financial Services Commission – Digital Asset Management Limited – Regulated Entity Entry: https://www.fsc.gi/regulated-entity/digital-asset-management-ltd-24738

Gibraltar Financial Services Commission – DLT Providers List: https://www.fsc.gi/regulated-entities/dlt-providers-38

Government of Gibraltar – Press Release 160/2019: DLT Licence Granted: https://www.gibraltar.gov.gi/new/sites/default/files/press/2019/Press%20Releases/160- 2019.pdf

Damex – OTC Client Agreement: https://assets.damex.io/otc-direct-terms Damex – Master Terms: https://assets.damex.io/direct-t%26cs

Damex – Terms and Conditions: https://damex.io/damex-terms-and-conditions/ Damex – Disclaimer: https://damex.io/disclaimer

Gibraltar Finance – Distributed Ledger Technology Framework Overview: https://www.gibraltarfinance.gi/technology/distributed-ledger-technology

GFSC – Distributed Ledger Technology Providers (overview page): https://www.fsc.gi/FSC/distributed-ledger-technology-providers

GFSC – Guidance and downloads for DLT firms: https://www.fsc.gi/downloads?section=19&type=0

Ramparts Law – Gibraltar DLT and Crypto Asset Law Overview: https://ramparts.gi/gibraltar-dlt-crypto-asset-law-and-regulation/

Global Legal Insights – Blockchain & Cryptocurrency Laws and Regulations: Gibraltar: https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and- regulations/gibraltar/

Sky News – Ziglu acquisition of Damex retail arm: https://news.sky.com/story/trading- platform-ziglu-adds-customers-with-acquisition-of-damex-arm-13232792

Gibraltar Chronicle – Damex sells retail arm to Ziglu: https://www.chronicle.gi/damex-sells-retail-arm-to-uk-crypto-banking-app-ziglu/

Tech.eu – Ziglu buys retail arm of Gibraltar-based crypto payments firm: https://tech.eu/2024/10/14/uk-crypto-outfit-ziglu-buys-retail-arm-of-gibraltar-based-crypto- payments-firm/

GFSC – Example enforcement notice (Tap Global Limited): https://www.fsc.gi/news/regulatory- settlement-agreement-between-the-gfsc-and-tap-global-limited-500

 

Authorities and contacts for formal complaints or information-sharing

1. Gibraltar (Part 2: DLT compliance and founding jurisdiction)
   • Gibraltar Financial Services Commission (GFSC) – To report issues concerning Distributed Ledger Technology licensing or regulatory conduct: https://www.gfsc.gi/consumer/submit-a-complaint
2. Lithuania (Part 3: io UAB and substance requirements)
   • Bank of Lithuania (Lietuvos Bankas) – For supervision of EMI licences and AML oversight: https://www.lb.lt/en/contacts#contact_form
3. Malta (Part 4: Trustee structure and supervision)
   • Malta Financial Services Authority (MFSA) – For service provider oversight and fit-and-proper obligations: https://www.mfsa.mt/about-us/contact/
   • Financial Intelligence Analysis Unit (FIAU) – For AML, CFT and outsourcing enforcement concerns: https://fiau.gov.mt/contact/
4. Isle of Man (Part 5: Blackfridge EX and stablecoin supervision)
   • Isle of Man Financial Services Authority – For reporting issues regarding stablecoins, token issuance and financial supervision: https://www.iomfsa.im/complaints/
5. United Kingdom (Part 6: Modulr dependency and safeguarding concerns)
   • Financial Conduct Authority (FCA) – For EMI supervision, safeguarding failures or third-party reliance risks: https://www.fca.org.uk/contact
6. Europe-wide (cross-border issues relevant to Part 7)
   • European Banking Authority (EBA) – For passporting, prudential and safeguarding breaches: https://www.eba.europa.eu/about-us/contact-us
   • European Securities and Markets Authority (ESMA) – For crypto-asset regulations and MiCAR application feedback: https://www.esma.europa.eu/contact-us
7. Optional for whistleblower protection and reporting
   • Financial Action Task Force (FATF) – For global AML/CFT framework enforcement: https://www.fatf-gafi.org/en/contact.html
   • International Association of Gaming Regulators (IAGR) – If broader concerns involve payment infrastructure for high-risk verticals: https://iagr.org/contact/