Obtain an FCA Licence with The Payment Practice

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Crypto firms that provide services in or into the UK may fall within the scope of regulation and must register with the FCA if they carry on certain cryptoasset activities by way of business. Under the UK’s money-laundering regulations, cryptoasset services that trigger this requirement include activities such as operating a cryptoasset exchange, arranging or facilitating the exchange of cryptoassets for money or other cryptoassets, providing custody services for cryptoassets, and similar services offered commercially to customers. Registration is required before these services can be provided in the UK, including where the activity is conducted from outside the UK but marketed into or accessible by UK users.

The FCA’s current focus for crypto registration is on ensuring that firms conducting regulated cryptoasset services can meet robust compliance and financial crime obligations. When applying, the FCA expects clear and comprehensive descriptions of the crypto products and services the firm intends to provide, including any planned future developments, as well as how these sit alongside any non-crypto activities. Applicants should describe their target customer base and the rationale for their business model, provide realistic financial information, and explain their fee structures. The FCA also expects detail on governance arrangements, including management structure, roles and responsibilities, and how the compliance and risk functions will operate. Information on ownership and control, including beneficial owners and senior managers, forms part of the assessment.

The FCA treats crypto registration as a substantive assessment rather than a formality. Firms must demonstrate that they understand and are prepared to comply with ongoing obligations under the money-laundering regime and should not expect the FCA to act as an adviser during the application process. Registrations that lack the necessary information or fail to show that appropriate standards can be met are at risk of rejection or referral back for further work.

The FCA application process is comprehensive and evidence-driven. Firms are expected to demonstrate, at the point of application, that they meet the relevant threshold conditions and are operationally ready to carry on regulated activities on an ongoing basis. This goes well beyond completing an application form.

Applicants are required to provide detailed information covering their business model, programme of operations, customer journeys, transaction and fund flows, governance and management arrangements, financial crime controls, safeguarding of client funds where applicable, financial resources, forecasts and wind-down planning. The FCA will also assess operational resilience, IT and data security, outsourcing arrangements and the suitability of directors and senior management. In many cases, the FCA will raise follow-up questions and may require meetings or interviews before reaching a decision.

Our role is to guide firms through this process in a structured and proportionate way.

We start by identifying which licence or permissions are most appropriate for your business model, growth plans and geographic footprint. This includes regulatory perimeter analysis and assessing whether a small or fully authorised regime is suitable.

We then secure and manage access to the FCA application portal, ensuring submissions are made correctly and supporting information is uploaded in line with FCA expectations.

We help prepare all required application materials and supporting documentation, including regulatory policies and procedures, programme of operations, safeguarding frameworks, financial models and forecasts, governance documentation and risk assessments.

Where safeguarding is required, we assist in designing appropriate safeguarding structures and introduce suitable safeguarding account providers and liquidity partners aligned with your regulatory status and operating model.

Throughout the application process, we handle ongoing communications with the FCA, manage regulatory information requests, and help respond clearly and consistently to supervisory questions.

We also prepare directors and senior managers for FCA interviews and meetings, ensuring they are confident in explaining the business model, risks, controls and governance arrangements.

Our focus is on ensuring applications are well-structured, credible and regulator-ready, reducing delays and helping firms enter the market on a compliant and sustainable footing.