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 […]
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. […]