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The Rules That Are Already Being Enforced Some firms are still treating crypto financial promotions as a regulatory work in progress. It isn’t. The rules have been in force since October 2023, the FCA has been enforcing them, and the pace of intervention is increasing. If your marketing hasn’t been reviewed against the regime, that...

  Financial crime failings remain the number one reason crypto firms face delays, challenges, or outright refusal during the application process. In most cases, the issue isn’t that firms don’t take compliance seriously. It’s that their framework hasn’t evolved to reflect the realities of digital assets and modern regulatory expectations. Strong AML for crypto firms...

  Crypto firms have had breathing room in the UK anti-money laundering perimeter. That’s ending. Two regulatory moves are about to bring crypto compliance to parity with traditional banking. The window to get ahead is now—not in 2027. February 2027: Correspondent Banking Rules Arrive for Crypto Crypto is already inside the UK anti-money laundering perimeter...

  Your compliance team is probably focused on the big regulatory headlines. But the real work in 2026 is in the details—and the firms that miss these three changes will pay for it later. Change 1: Pooled Accounts Are Under the Microscope The draft Money Laundering Regulations 2026 amendments don’t require full Customer Due Diligence...

    “We’re decentralised” has become the crypto industry’s favourite regulatory defence. The assumption is that if no single entity controls a protocol, no single entity can be regulated. It’s a compelling argument in theory. In practice, the FCA is not buying it — and if your business sits anywhere near a DeFi protocol, you...

Exchanges are the front door of the crypto market. They’re where most people buy, sell and trade — and they’re where the most high-profile failures have happened. The FCA knows this, and exchange operators applying for authorisation through the September 2026 gateway should expect a higher level of scrutiny than almost any other applicant category....

Stablecoins are supposed to be the straightforward part of crypto. Pegged to fiat, predictable in value, useful for payments and settlement. But from a regulatory perspective, they’re anything but simple. Stablecoins sit in a grey zone between two different licensing frameworks, and getting the wrong one — or not realising you need both — can...

If your business holds other people’s crypto, the FCA is paying close attention. Custody is one of the highest-risk permission categories in the new cryptoasset regime, and the requirements go well beyond what most firms currently have in place. Whether you’re a dedicated custodian, a platform that holds assets on behalf of users, or a...

The FCA has made a pre-application support service available specifically for firms preparing cryptoasset authorisation applications. This is one of the most useful tools available to firms right now — and one of the least used. Many firms do not know the service exists, and those that do often underestimate its value or misunderstand how...

You already know the dates. The FCA’s cryptoasset authorisation gateway opens on 30 September 2026 and closes on 28 February 2027. You probably also know that firms applying during this window get transitional arrangements allowing them to continue operating. But what actually happens if you don’t apply in time? The consequences are more severe —...

When the FCA says it expects firms to “prepare early” for the cryptoasset authorisation gateway, what does that actually mean in practice? It means building evidence across the three areas that the FCA weights most heavily in any authorisation assessment: governance, systems and controls. These are not separate boxes to tick — they are interconnected,...

    The FCA’s transitional arrangements for the new cryptoasset regime are widely misunderstood. The headline is simple: apply during the gateway window (30 September 2026 to 28 February 2027) and you can continue operating after the regime starts on 25 October 2027. But the detail matters. The transitional provisions are not a blanket licence...

If you are a new entrant preparing for the FCA’s cryptoasset authorisation gateway in September 2026, the compliance framework you submit is not a supporting document — it is the application. A weak framework means delays, additional information requests or refusal. Here is the sequence of work and where to focus your effort.   The...

There is a common assumption that the FCA’s upcoming cryptoasset regime only affects unregulated firms or those with AML registration. That’s incorrect. If your firm is already authorised under FSMA and carries out — or plans to carry out — cryptoasset activities, you must apply for a variation of permissions (VoP) during the gateway window...

  If you operate a cryptoasset business in the UK — or plan to — the regulatory landscape is about to change fundamentally. The FCA is replacing light-touch AML registration with full FSMA authorisation, bringing crypto firms under the same framework as traditional financial services: governance requirements, prudential standards, conduct rules, Consumer Duty and significantly...

Five months sounds reasonable. The FCA’s authorisation gateway for cryptoasset permissions opens on 30 September 2026 and closes on 28 February 2027. Plenty of time? Not even close. When you work backwards from the deadline and account for what actually needs to happen, most firms will find they are already behind.   The Timeline Trap...

The clock is ticking. The FCA has confirmed a five-month authorisation window — 30 September 2026 to 28 February 2027 — for firms to secure or vary their cryptoasset permissions ahead of the new regime taking full effect on 25 October 2027. Whether you’re a new entrant or an existing FSMA-authorised firm, this window is...

Further to our previous blog on the Consumer Duty implementation plan, which should have been completed at the end of October, we wanted to outline the next steps. If you haven’t completed your implementation plan yet, it is imperative that you do. We can help you catch up the curve, please get in touch. The...