United Kingdom
An MLR registration regime today, moving toward full FCA authorisation of cryptoasset activities as regulated activities.
Who regulates this
Financial Conduct AuthorityFCA
Cryptoasset businesses under the Money Laundering Regulations 2017, plus the financial promotions regime for cryptoasset marketing.
Licences and permissions
MLR cryptoasset registration
Exchange and custodian wallet providers with a UK nexus.
Historically a very low approval rate. The FCA has been public about the standard of applications it receives.
Financial promotions compliance
Any marketing of cryptoassets to UK consumers.
In force since October 2023, with prescribed risk warnings, a cooling-off period and appropriateness assessments.
What it takes
Capital
No prudential capital under the MLR route. The forthcoming authorisation regime is expected to introduce one.
Timeline
Nine to eighteen months for MLR registration has been common. Plan generously.
Substance
UK establishment and a UK-resident MLRO with genuine seniority and sector experience.
Where a software vendor sits
Supplying software is not a registrable activity. The FCA's operational-resilience and outsourcing expectations nonetheless reach material third-party technology providers through the firms that use them.
What catches people out
The financial-promotions rules catch far more than firms expect, including a lot of ordinary product marketing, and they bite on communications capable of having an effect in the UK regardless of where the firm sits.
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