Receiving regulator approval to operate in Gibraltar is anything but easy, crypto derivatives exchange ZUBR told CoinDesk.

ZUBR, which began trading in March, said Wednesday it had received in-principle approval from the Gibraltar Financial Services Commission (GFSC) as a Distributed Ledger Technology (DLT) provider. The approval is on the condition the exchange addresses some of the regulator's feedback by the time it gets its license.

But just getting to this point has proven difficult.

"From day one we realized 100 percent...that we would have to sacrifice a lot to get into the regulated space," co-founder Oleg Ravnushkin said. Even before the regulator provided feedback, ZUBR capped its maximum leverage at 20x and introduced high entry barriers to ensure it only served professional, not retail, clients.

The GFSC has offered DLT licenses since the beginning of 2018. Based on nine very general principles – including one clause that an applicant "must conduct its business with honesty and integrity" – the license provides a broad-stroke and flexible regulatory framework for any activity that comes under the umbrella of DLT, such as to transmit or store value on behalf of others.

Around a dozen companies have a Gibraltar DLT license, including the blockchain subsidiary for the Gibraltar Stock Exchange. Ravnushkin said there's probably another 12 more entities going through the application process, alongside themselves.

See also: Crypto Derivatives Platform Gets Nod From London Stock Exchange’s Software Tester

Nine principles may seem like an overly simplistic framework, but ZUBR disagrees.

"It took us a preliminary application to go through to a full application stage; to go through to a set of interviews with key [GFSC] personnel, [then] a set of presentations of our business model and a number of rounds of follow-up discussions and additional requests made by the regulator to have clarity on very specific questions," ZUBR's chief legal officer, Olga Okuneva, said.

"It's not that straightforward to just come and get a Gibraltar license...[Y]ou cannot just, you know, switch to Gibraltar," Ravnushkin said. "We had to be comfortable with a lot of additional, you know, checks and outsourcing providers to make sure that the trading was transparent and that the market structure was solid so there's no manipulation whatsoever."

"It's going to be 10 principles pretty soon," he added.

Neither Ravnushkin nor Okuneva described the regulatory feedback as "changes," but rather "more of a fine-tuning of something we have discussed thoroughly with the regulator," Okuneva said.

Ravnishkin said this could include relocating more of their staff to Gibraltar, but added: "I cannot obviously comment on the exact nature of this."

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But Ravnishkin confirmed none of the changes will affect its core business model. That's probably a relief. ZUBR forked out £30,000 (~US$37,000) just for the application fee for the category three license, which covers companies dealing with complicated assets, including crypto derivatives.

Having first submitted its license more than 12 months ago, Ravnushkin reckons ZUBR will still have to wait for a few months before it receive its full license.

"We'd love to have it tomorrow," he said.