Some crypto firms are treating September as a distant deadline. It isn’t. The FCA’s authorisation application window opens on 30 September 2026 – that is less than four months away and the firms that are not prepared by then face consequences that go well beyond a compliance gap. This is not an extension of the...
The Question Most Boards Haven’t Answered Clearly Payment and e-money firms have spent the past nine months preparing for CASS 15. Policies have been written, auditors engaged, reconciliation processes reviewed. But there is one question that often goes unresolved even in well-prepared firms: if the safeguarding framework fails, who is personally accountable? Not the firm....
The Deadline Has Passed. The Work Has Not. On 7 May 2026, CASS 15 came into force. The FCA’s new safeguarding regime for payment and e-money firms is no longer something to prepare for — it is something firms are now expected to demonstrate compliance with, from day one. For some firms, that is a...
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...
“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....
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,...
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...
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...
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LHI Consulting
LHI Consulting is a trading style of LHI Holdings Ltd which is a company registered in England and Wales registered number: 11496647.
GET IN TOUCHRegistered Address
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W1T 6EBLHI Consulting
LHI Consulting is a trading style of LHI (Holdings) Ltd which is a company registered in England and Wales registered number: 11496647.
GET IN TOUCHRegistered Address
Spectrum House,
2b Sutton Lane,
Hornchurch,
Essex, United Kingdom,
RM12 6RJCorrespondence Address
LHI Holdings Ltd
4th Floor Silverstream House
45 Fitzroy Street
London
W1T 6EB