Cryptoassets: How to apply for registration

We expect applicant firms to display a comprehensive understanding of the UK AML/CTF regime as documented in the MLRs[3]. You should make sure you understand all the obligations and expectations that will be placed on you.

Review the cryptoasset registration forms so you know what information and documents we require. You can review the forms via our Connect[4] system. 

For information only, see copies of the registration application form[5] and the MLR individual application form[6]. These copies are not to be used; applications must be submitted via Connect[4]. 

Pre-application meetings are free of charge and provide an opportunity to outline your plans and get initial, informal feedback from us. We will usually request documentation is submitted in advance of the meeting so that we can familiarise ourselves with your firm’s proposed business model. This should cover your proposed business model (including customer types, products and services, jurisdictions and flow of funds), details of your proposed AML framework, and documentation and details of the proposed senior managers.

A pre-application meeting can be requested at any stage in a firm’s preparations. Firms should be aware that feedback given as part of this process may result in further work being needed prior to an application being submitted. Pre-application meetings may be particularly helpful if a previous application has been rejected or withdrawn.

You can request a pre-application meeting via our Connect[7] system.

See the PASS page[6] for more details on this service and its benefits.

You may also wish to consider seeking independent legal or compliance advice.

The FCA cannot recommend or endorse any compliance or advisory firms.

There are restrictions on the use of certain financial services-related words or expressions in company registered names and/or trading names. Applicants should review our information about trading names[7] and sensitive business names[8].

Under Regulation 21(3)[9] of the MLRs, an applicant must appoint a Money Laundering Reporting Officer (MLRO)/Nominated Officer.

We expect this individual to have appropriate knowledge of UK regulation, experience (including knowledge of cryptoassets) and training, as well as a level of authority and independence to enable them to monitor and manage compliance with policies, procedures and controls to carry out their role and responsibilities under the MLRs.

We expect the MLRO to be heavily involved in the preparation of an application for registration. We also expect the MLRO to remain in place throughout the application process and beyond, if the firm were to be registered. Changing the MLRO may result in significant delays to your application and the overall outcome.

We will assess their fitness and propriety as part of our assessment.

Find out more on our expectations of an MLRO[10].

Make sure you answer every question fully and provide all the information requested. Omissions may result in your submission being rejected. If we do ask for further information, you should provide it promptly.

A continued failure to provide the information we request may lead to your application being refused.

The information and documents you supply should be up to date (as on the date of submission), specific (do not use generic documents if they are not fit for purpose), and have been reviewed thoroughly (final versions) and signed off (via appropriate governance).

We will not review and comment on draft documents as part of our assessment.

Make sure you fully disclose any information we require. We take non-disclosure of information that could impact our assessment very seriously, especially if we find that you have withheld information deliberately or have provided false or incomplete information. Giving us false or misleading information may be a criminal offence and could lead to the refusal of your application.

The success of your application could be affected. If in doubt, it is better to disclose information rather than withhold it.

The declaration must be signed by the appropriate person(s) who are responsible for making the application on behalf of the applicant firm. The appropriate person(s) depends on the nature of the applicant firm:

When you submit your application you will need to pay a fee to register with us. Cryptoasset registration falls into Category 6 of our pricing categories[11].

Note: You will also need to pay annual (periodic) fees[12] while your firm is registered with the FCA.

For the purposes of calculating fees, we have defined income as the gross inflow from economic benefits (that is: cash, receivables and other assets) recognised in the registered UK entity’s accounts during the reporting year in relation to the provision of the cryptoasset services specified in the MLRs.

Many applicants find it helpful to have an adviser or consultant support them in preparing their application, or to get ready for meetings or interviews. However, firms remain accountable for their applications, and should be able to explain to us all the material in it.

If relevant, applicants can provide letters of goodstanding from other regulators. However, we will make our own enquiries with overseas regulators, if appropriate.

Applicants should be proactive and self-reliant. They should not expect the FCA to act as an advisor when completing their application or to recommend solutions when we highlight any deficiencies.

If you need to correct or make any changes to your application after it has been submitted, complete transparency and timely disclosure is very important. You should also provide us with any new information that could affect our assessment promptly.

If there are significant changes, your case officer may request that you consider withdrawing your application and reapplying when you have been able to prepare an updated application.

Applicants should show they are agile and prepared to deal with a rapidly evolving regulatory framework, including responding to emerging risks and industry changes, and tracking financial crime typologies and new requirements that could affect their operations.

Applicants must not use their application to promote their products or services. Applicants’ websites and marketing material must not include language that gives the impression that making an application for registration is a form of endorsement or recommendation by the FCA.

Applicants must recognise that being registered is not a one-off formality or a tick-box exercise without any further obligations or interaction with us. Applicants must continue to make sure they comply with the requirements of the MLRs and understand that we will supervise this compliance.

If we decide that your firm meets the requirements for registration, we will approve your application. At which point we will write to you to confirm your registration, tell you your Firm Reference Number (FRN) and you will be added to the Financial Services Register[11].

Your firm will then be handed over to our supervision team who will engage with you as necessary. We supervise most firms as a portfolio – grouping firms that share a common business model together. We may also provide dedicated supervisory oversight to firms with the greatest potential impact on consumers or their relevant markets particularly where firms operate globally.

After registration, if you need to update the details we hold for you or change something you will need to tell us via Connect[16]. You can also contact us[9] if you need help.

We will reject your submission without conducting an assessment if it does not contain the minimum information we ask for. Under these circumstances, we'll explain the reason(s) we have rejected your submission and we may refund your application fee.

You can resubmit an application, containing all the relevant information, at any time. We may offer you the opportunity to engage in our pre-app process before you resubmit.

You can ask us to withdraw your application at any time during the registration process.  Common reasons for doing this are:

• Not being able to show that you meet the required standards at the point of submission.
• Needing time to produce or gather missing information to address our concerns.
• Understanding that registration is likely to be refused.

If you withdraw your application, your application fee will not be refunded.

However, it is possible to reapply any time after you have withdrawn your application. Many firms choose to withdraw and reapply once they’ve addressed our feedback. If you do reapply, a new application fee will be payable.

Accepting a notification to withdraw an application remains at our discretion.

If we think that an applicant firm does not meet the standard for registration, we’ll recommend to an FCA decision-maker that its application is refused. Under these circumstances, we will send a Warning Notice setting out our reasons for refusing your application. At this point, you can notify us that you want to withdraw your application (as above, accepting a notification to withdraw an application remains at our discretion) or if you don't agree with our decision, you can make representations to the FCA decision maker.

If your representations are successful, we will register your firm. If we do not agree with your representations, we’ll send you a Decision Notice. If you still do not agree with our decision, you can refer our decision to the Upper Tribunal[10]. If the Upper Tribunal agrees with our decision, we’ll publish a Final Notice.

If we refuse your application, your application fee will not be refunded.

Find out more about our refusal process[11].