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United Kingdom Financial Conduct Authority Strengthens AML/CTF Registration Requirements for Cryptoasset Firms

On 17 April 2025, the United Kingdom Financial Conduct Authority (UK FCA) updated the anti-money laundering and counter-terrorist financing (AML/CTF) registration regime and thereby reaffirmed its commitment to combatting money laundering, terrorist financing, and proliferation financing in the cryptoasset sector. As the designated AML/CTF supervisor of United Kingdom cryptoasset businesses under the United Kingdom Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs), the UK FCA mandates that any firm providing cryptoasset services within the scope of the MLRs must be formally registered before commencing operations.

Firms intending to operate cryptoasset businesses “by way of business” within the United Kingdom must assess their activities against Regulations 8, 9, and 14A of the MLRs. This includes businesses already authorised or registered with the UK FCA under other frameworks, such as payment institutions, electronic money institutions, and firms authorised under the United Kingdom Financial Services and Markets Act 2000 (FSMA). The UK FCA will assess on a case-by-case basis whether an activity qualifies as being conducted in the course of business within the jurisdiction.

In addition to the general AML/CTF obligations, cryptoasset firms that intend to communicate financial promotions in the United Kingdom under the expanded scope of the Financial Promotions Regime must also seek registration under the MLRs. This ensures alignment between anti-money laundering supervision and consumer protection initiatives.

Applications for registration must be submitted through the UK FCA’s Connect system. Prior to filing, firms are strongly encouraged to review the cryptoasset registration application forms, guidance on good and poor-quality applications, and the detailed informational requirements outlined by the UK FCA. The authority has made it clear that poor-quality, incomplete, or misleading applications will be rejected outright without further assessment. Only once all necessary information has been received will the UK FCA begin its three-month statutory clock to render a decision.

Recognising the complexity of the regime, the UK FCA offers firms the opportunity to request pre-application meetings to discuss expectations, clarify application processes, and introduce business models. These meetings, while highly valuable, do not constitute pre-approval or advice. Firms seeking such meetings must submit key information in advance, including corporate details, relevant regulatory questions, a summary deck outlining business models and product offerings, and the cryptoasset activities intended to be pursued.

Registration fees apply under Category 6 of the UK FCA’s application pricing structure, with additional periodic or annual fees applicable for registered firms. Income is defined for fee purposes as the gross inflow of economic benefits generated from providing cryptoasset services during the reporting year.

Fit and proper assessments form a core pillar of the registration review process. The UK FCA will scrutinise not only the applicant business but also all relevant individuals, including directors, managers, nominated officers for anti-money laundering compliance, and beneficial owners, in accordance with Regulation 58A of the MLRs. Criteria considered include criminal convictions, regulatory compliance history, financial soundness, honesty, integrity, competence, and the risk profile presented by the applicant in the context of money laundering and terrorist financing vulnerabilities.

The UK FCA has issued a stern reminder that non-disclosure of relevant information during the application process is treated extremely seriously. Any deliberate withholding of information or submission of false or misleading facts may result in automatic rejection of the application and potential criminal proceedings.

Throughout the registration process, applicants are expected to demonstrate a proactive understanding of their regulatory obligations, a strong culture of compliance, and operational readiness to meet ongoing AML/CTF requirements.

Firms seeking further guidance or clarification regarding the cryptoasset registration regime are encouraged to contact the United Kingdom Financial Conduct Authority’s dedicated email channel at firm.queries@fca.org.uk.

(Source: https://www.fca.org.uk/news/speeches/global-responses-digital-asset-regulation)