Digital Asset Licences: BMA Technology Package

CLIENTS | DIGITAL ASSETS
Digital Asset Licences: The Technology Package the BMA Asks For
Adam Wenham | Founder & Managing Director, Garrison
In brief
The BMA's guidance for prospective applicants asks for a technology, custody and outsourcing package, matured by licence class.
After the licence, the Bermuda board stands behind an annual cyber risk return, the custody code, PIPA and, for Class F, the resilience code from 2028.
Garrison writes and evidences the package with the applicant and its lawyers, then keeps the evidence current.
The package is matured by class, and Class F must be board-approved
The BMA's guidance note for prospective applicants (September 2025) asks for the technology, custody and outsourcing package to be attached to the application, at a maturity that rises with the licence class.
Exhibit 1. What the BMA expects by class
Source: BMA, guidance note for prospective applicants, September 2025.
Five parts, each evidenced before it is filed
Exhibit 2. The technology package
Specialists for keys, smart contracts and ledger security are named in the engagement letter and work under Garrison's accountability.
Your lawyers keep the application; Garrison supplies the technology
The application, business plan, custody agreements, contracts, AML and conduct policies, legal advice and the meetings with the Authority stay with your law firm. Garrison writes and evidences the technology sections alongside them, in about six weeks for most applicants.
After the licence, the Bermuda board signs for technology run from abroad
Most licensees run technology from a parent or affiliate abroad with a small team in Bermuda. The Authority still tests the Bermuda board's evidence.
Every answer in your cyber risk return traced to evidence before it is signed.
One review across the DAB cyber code, the custody code, PIPA and, for Class F, readiness for the resilience code.
A named technology or operational risk lead in Bermuda, where the licence needs one.
Next step
Thirty minutes on your application or your first return, on-island or by call. No cost, no pitch. adam@garrison.re · +1 441 732 2308. Law firms: ask for the partner brief.
About the author. Adam Wenham is the founder of Garrison, a Bermuda firm that provides senior technology leadership to Bermuda's regulated firms: covering technology seats, running programmes, bringing in specialists and getting firms ready for the BMA's technology codes. He led technology transformation and operational resilience at the Bank of England, held senior roles across operations, engineering, architecture, innovation and change during seventeen years at Credit Suisse, and led the technology modernisation function at StoneX. At both Credit Suisse and StoneX he led the technology side of mergers and acquisitions. He began his career at Barclays, where he ran the technology for the move of BZW's 3,500-strong investment bank and its 1,300-position dealing room to Canary Wharf. adam@garrison.re
Garrison · Hamilton, Bermuda · adam@garrison.re · Practitioner analysis, not legal advice.