September Is On Its Way: Your Pre-Autumn Compliance Checklist
The FCA’s crypto authorisation window opens soon. If your firm is planning to submit an application — or is already operating in a way that requires authorisation – the time to have addressed the gaps in your compliance framework was before this week. But for firms that still have outstanding items, the next seven days […]
Section 21 Approvals for Crypto Promotions: What’s Changed and What It Means for Your Firm
When the FCA’s financial promotions regime for cryptoassets came into force in October 2023, firms that were not themselves authorised or registered needed a route to communicate financial promotions legally. The section 21 approval route — under which an FCA-authorised person approves a promotion on behalf of an unauthorised firm — provided that route. Many […]
Affiliate Marketing and Crypto Promotions: Where Firms Are Exposed Without Knowing It
The principle has been established clearly in earlier pieces in this series: firms are responsible for every financial promotion that reaches UK consumers on their behalf, whether they created it or not. If an affiliate publishes a non-compliant promotion for your product, the exposure is yours. The FCA has said so explicitly, and its enforcement […]
GDPR and Crypto Onboarding: Where Firms Are Exposed Without Realising It
Crypto firms spend significant time and resource building onboarding processes that satisfy the FCA. KYC checks, AML screening, appropriateness assessments, risk warnings, cooling-off periods — the regulatory requirements are well understood, and most firms have invested in meeting them. What far fewer firms have done is ask a separate but equally important question: is the […]
The 5 Things the FCA Found Wrong With Crypto Promotions
When the FCA set out to assess how firms were responding to the crypto financial promotions regime, it wasn’t looking for edge cases or obscure technical failures. What it found were the same problems, at firm after firm, across the same five areas. None of them are surprising. Most of them stem not […]
Financial Promotions for Crypto: 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 is a gap that needs closing […]
FCA Crypto Authorisation: Beyond AML Registration
The FCA’s Money Laundering Regulations registration has one focus: whether a firm has adequate controls to prevent financial crime. It is a threshold test, not a comprehensive review. Authorisation is different in kind, not just in degree. The FCA will assess five things it has never previously assessed for most crypto firms. Business […]
The FCA’s Crypto Authorisation Window Opens in September. Here Is What That Means for Your Firm.
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 […]
When Safeguarding Goes Wrong, Who Is Personally Responsible?
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. […]