Bybit — Unregistered Overseas Crypto Asset Exchange (Japan FSA Warning 3 Times)
ConfidenceLikelyUpdated2026-07-29Review by2027-01-29Sources6Machine-translatedOriginal (JA)
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This entry sits under exchanges index. Read it with FSA crypto-asset exchange registration system — number system / Local Finance Bureau jurisdiction / registration requirements for adjacent context and Japan Financial Regulation — Legal Framework for Tokens, Crypto Assets, and Payments for the broader system boundary.
No crypto asset exchange registration in Japan · FSA warning letters issued three times (2021-05 / 2023-03 / 2024-11) · Non-member of JVCEA
1. Legal Entity and Shareholders
- Brand name: Bybit
- Official legal name: Bybit Fintech Limited
- Incorporated: 2018 (Singapore)
- Headquarters: Dubai (United Arab Emirates). Headquarters relocated from Singapore to Dubai in 2022.
- Founder: Ben Zhou (Singaporean entrepreneur). Continues to lead the company as CEO.
2. Licenses and Registration Status
- Japan crypto asset exchange registration: None (unregistered)
- Japan FSA warning letters: 3 letters issued in total (see §6 for details)
- JVCEA membership: Non-member
- UAE (VARA): Operating under the supervision of Dubai’s Virtual Assets Regulatory Authority (VARA). Following the 2022 relocation, UAE serves as the primary regulatory jurisdiction.
- India (FIU-IND): Completed registration with India’s Financial Intelligence Unit (FIU-IND) in February 2025. Simultaneously paid a penalty of INR 92.7 million (approximately JPY 110 million) for prior unregistered operations.
- Other regulators: Temporarily suspended services to UK residents following the FCA’s crypto asset derivatives ban issued in 2021. Records of warnings and restrictions exist across multiple jurisdictions including Europe and Canada.
3. Supported Assets
- The FSA warning materials do not describe Bybit’s supported assets or product mix. This entry therefore does not infer an asset count or the later availability of products to Japan residents.
4. Business Scope
- The FSA warning materials do not enumerate Bybit’s products or funding functions. This entry is limited to the regulatory fact of unregistered business at the warning dates and does not freeze a current product list.
5. Market Share and Trading Volume
- The FSA warning materials contain no comparable figures for Bybit’s Japan trading volume, account count, or market share. This entry does not infer a global rank or a Japan-market position.
6. History and Significant Events
The table includes only Japan-facing warnings confirmed in the FSA publication “Issuance of Warning Letters to Crypto-Asset Exchange Operators, etc.” Each row summarizes the publication date, location, and warning reason in that material; it is not a complete corporate history of Bybit or a record of overseas events. ^[Source: https://www.fsa.go.jp/policy/virtual_currency02/index.html.]
| Period | Event |
|---|---|
| 2021-05-28 | First FSA warning: warned for conducting unregistered crypto-asset exchange business with Japan residents as counterparties |
| 2023-03-31 | Second FSA warning: warned again for the same unregistered-business reason |
| 2024-11-28 | Third FSA warning: warned again for the same reason, with Dubai listed as the location |
7. Strategic Developments
- Japanese regulatory issue: The FSA publication lists warnings to Bybit Fintech Limited for unregistered business on 2021-05-28, 2023-03-31, and 2024-11-28. This entry does not infer later account-registration, app-distribution, or service-termination dates from that material alone. See also FSA overseas exchange warning system.
8. Key Persons
- Ben Zhou (CEO and founder): Singaporean entrepreneur. Has led the company as CEO since founding Bybit in 2018. Drew attention for personally addressing the situation on X (formerly Twitter) and leading a rapid response following the February 2025 hack.
- Details of other key executives and investors are not included as they cannot be confirmed from public sources.
Related
- japan-financial-regulation — Japan financial regulation overview
- jp-foreign-exchange-kucoin — 2024-11-28 simultaneous warning target (KuCoin)
- jp-foreign-exchange-bitget — Same, Bitget
- jp-exchange-binance-japan — Binance Japan incorporation and formal registration case (structural contrast with Bybit)
- bybit-lazarus-hack-detailed-analysis — Detailed analysis of Bybit Lazarus hack
- global-vasp-regulatory-comparison-matrix — Global VASP regulatory comparison matrix
- uae-vara-licensing-overview — UAE VARA licence overview (Bybit’s home jurisdiction)
- fsa-foreign-exchange-warning-system — FSA warning system for overseas exchanges
Sources
- FSA Crypto Asset and Electronic Payment Instruments page (retrieved 2026-05-19)
- Atarashii Keizai — FSA issues warnings to overseas unregistered crypto asset exchanges (2024-11-28) (retrieved 2026-05-19)
- Bybit — Wikipedia (retrieved 2026-05-19 · history, hack details, and litigation sourced from primary reporting by Bloomberg, NYT, BBC, CNBC, TechCrunch, etc.)
- Finance Magnates — FSA Warns of Bybit Operating Unregistered Crypto Services in Japan (2021-05) (retrieved 2026-05-19)
- CoinPost — Bybit FSA-related article list (retrieved 2026-05-19)
- TheStreet — Japan blocks major crypto exchanges from App Store and Google Play (2025-02-07) (retrieved 2026-05-19)
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