We are committed to being the most trusted digital asset exchange.

Operating with a mature approach, we prioritize crypto compliance and safeguarding customer assets through robust security measures and regulatory oversight.

50+

Jurisdictions

Assets listed

100+

Markets

$1.5 tn+

Total volume traded

Independently audited by Deloitte.

Our annual financial statements are prepared in accordance with International Financial Reporting Standards (IFRS) and audited by Deloitte & Touche LLP.

Audited financial statements

January 1, 2023 to December 31, 2023

January 1, 2022 to December 31, 2022

January 1, 2021 to December 31, 2021

SEC financials

Form F1 July 18, 2025

Secure by design.

Bullish’s hardware, software, and operational safeguards ensure platform security and the safety of customer funds. We operate as a full reserve exchange, ensuring that customer assets are consistently maintained in a 1:1 ratio and segregated from Bullish assets.

Licensed and regulated.

HONG KONG – We have received Types 1, 7 and Virtual Asset Trading Platform licenses from the Hong Kong Securities and Futures Commission (CE No BUQ958).

Bullish HK Markets Limited Regulatory Status

GIBRALTAR - Bullish is operated by Bullish (GI) Limited and has been regulated by the Gibraltar Financial Services Commission (GFSC) as a Distributed Ledger Technology (DLT) provider since launch. The GFSC’s DLT regulatory regime is an investor protection-focused regime governed by 10 regulatory principles focused on honesty and integrity, customer care, risk management, protection of client assets, security, financial crime prevention, market integrity as well as adequate resources and sound governance.

Bullish (GI) Limited Regulatory Status

GERMANY – Bullish Europe GmbH (FKA Bullish DE Custody GmbH) is licensed by the Federal Financial Supervision Authority (Bundesanstalt für Finanzdienstleistungsaufsicht – “BaFin”) under BaFin-ID 162355 for the provision of crypto custody business (Kryptoverwahrgeschäft), principal broking (Finanzkommissionsgeschäft) and proprietary trading (Eigenhandel) regarding crypto assets (Kryptowerte) pursuant to the German Banking Act (Kreditwesengesetz – “KWG”). Bullish EU is positioned for EU wide expansion under the Markets in Crypto-Assets Regulation (MiCA) legal framework.

Bullish Europe GmbH regulatory status

Onboarding jurisdictions

Bullish is available to customers in over 50+ jurisdictions around the world.

Not all products available in all jurisdictions.

Get Started

Licenses applied for

UNITED STATES – We have registered as a money services business with FinCen and we are in the process of applying for money transmitter licenses and other state licenses to increase the portion of the U.S. States we can serve. See our Exchange Terms of Service for the current list of eligible States.

Bullish group divisions.

The Bullish group consists of primary divisions: Bullish, a regulated digital asset exchange, and a division dedicated to asset management.

The Board and related governance
The exchange’s Board of Directors (“the Board”) meet on at least a quarterly basis. The Board manages the Risk and Compliance Committee (“the Committee) composed of Risk, Compliance, and Internal Audit teams with an Independent Non-Executive Director (INED). The members are:

Regulatory oversight and responsible individuals
As part of being regulated, the GFSC mandates certain ‘Responsible Individuals (RIs)’ perform certain key roles. Each RI is required to be approved by the GFSC. The roles are:

Robert Quinlivan Head of Markets
David Harrington Head of Compliance, MLRO
Marc Diedert Head of Security
George Gaffney Head of Technology, COO
Randi Abernathy Head of Risk Management (temporary)
Russell Eldridge Head of Finance, Head of Business Continuity, Head of Customer Care, Head of Trading, Head of Operations, Head of Client Assets Oversight
Andrew Wynn Chair of Risk Committee
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Enterprise Risk Management
Bullish’s Enterprise Risk Management Framework (ERMF) provides oversight and guidance to managing risks including roles and responsibilities across its three lines of defense model (Compliance, Risk, Internal Audit teams). The ERMF establishes the process for identification, assessment, reporting and prioritizing risk across the firm and ensuring risks are managed within the defined risk appetite. There is also a monthly risk management meeting where different functional stakeholders contribute metrics to inform each other on key risk areas within the function with key takeaways reported to senior management. The Committee and the Board are informed of status updates on risk management tool implementation, action items and material risks.
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Compliance
As a key part of the Bullish Group, the exchange business is committed to maintaining the highest standards of compliance and integrity in all aspects of its operations. As a virtual asset exchange, we recognize the importance of complying with all applicable laws and regulations.
Status updates for Compliance, including breaches and action items are informed to the Committee and the Board on at least quarterly basis or more frequently as circumstances may determine.

Internal audit
The Internal Audit Function is the company’s third line of defense, reporting directly to the Bullish Global Board and the Boards of its regulated subsidiaries. It evaluates the effectiveness of Bullish Group’s internal control, risk management and governance processes using a risk-based approach and reports the results regularly to the Boards and senior management. To maintain its effectiveness, safeguards are in place to ensure its independence and objectivity.