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UK Sets 2026 Start for Crypto Licensing, Stresses Compliance

UK crypto firms face 2027 deadline for FCA authorization requiring robust compliance

  • UK crypto firms must transition from Money Laundering Regulations registration to full Financial Services and Markets Act authorization by October 2027.
  • A competent Money Laundering Reporting Officer and a robust, crypto-specific Business-Wide Risk Assessment are the cornerstones of a successful application.
  • The Financial Conduct Authority mandates that transaction monitoring and travel rule solutions must be fully explained and cover all products.
  • While AI use in compliance is permitted, firms must be able to explain the inputs and outcomes of any algorithms they deploy.
  • The authorization window opens on September 30, 2026, with a pre-application support service launching in July.

The UK’s new cryptoasset regime now has a definitive timeline, with the authorization window opening September 30, 2026, and the rules commencing October 25, 2027, as Parliament confirmed earlier this year. Consequently, the Financial Conduct Authority has clarified that existing high standards for anti-money laundering frameworks will remain under the new Financial Services and Markets Act regime.

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The FCA emphasized this point in its CP26/13 consultation, stating an investment in compliance now will not be regretted. Therefore, firms should focus on meeting current FCA expectations rather than guessing future requirements. Success hinges on appointing a competent Money Laundering Reporting Officer.

This officer must have adequate time, relevant crypto knowledge, and fitness for the role. However, combining the MLRO role with business development is a significant red flag for regulators. Meanwhile, the foundational document is a tailored Business-Wide Risk Assessment.

This assessment must identify and score inherent risks across five specific factors. A common pitfall, noted in a March webinar, is confusing control failures with inherent risks. Furthermore, a firm’s Customer Risk Assessment methodology must logically align with its BWRA findings.

Transaction monitoring systems must cover both fiat and on-chain activity, calibrated to the firm’s specific risk profile. Similarly, travel rule solutions require detailed explanation, including how counterparty discovery works. The FCA also permits the use of AI in compliance controls.

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A key condition is explainability, where firms can detail how an algorithm produces an outcome. Guidance from The Wolfsberg Group on AI serves as a useful reference for this principle. Firms with global operations can use overseas group controls if they meet UK standards.

The FCA will open a pre-application support service in July for firm-specific queries. Therefore, preparing a strong MLRO, tested BWRA, and explainable monitoring systems now is the most prudent path forward.

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