Quick actions

Crypto License

UK Crypto License

Prepare your FCA application for UK cryptoasset services

gb

Service Snapshot

Regulatory & Service Snapshot

Gofaizen & Sherle provides regulatory route assessment and licensing support for cryptoasset service providers, including exchanges, custodians and fintech groups. Receive a defined application scope and preparation plan covering registration under the Money Laundering Regulations (MLRs), financial promotions and the upcoming Financial Services and Markets Act 2000 (FSMA) regime.

  • Authority Financial Conduct Authority (FCA)
  • Current Route MLR registration for in-scope business
  • Upcoming Route FSMA Part 4A permission, with applications open
  • Application Submission through FCA Connect
  • Cost Professional fees quoted separately from official charges
  • Timeline Preparation assessed separately from regulator review
  • Result Application dossier and response support
  • Capital Assess funding against the selected permissions
  • Local Presence and Company Structure and operational requirements depend on the route
  • Banking Support Separately agreed scope

Which Cryptoasset Businesses Does This Fit?

sign positive

May fit

  • Exchange, custody and brokerage providers planning substantive UK operations
sign warning

May not fit

  • Businesses seeking one permission for worldwide operations or a model without customer checks

Requires Assessment: Overseas firms, mixed financial services and groups marketing to UK consumers

Which Regulatory Route Applies?

Registration, permission to operate and permission to market are different legal questions.

Registration or LicenseWhen It Applies
FCA cryptoasset registrationTrigger: In-scope exchange/custody business carried on in the UK; Legal Basis: MLRs; Status: Current; Authority: FCA; Outcome and Limits: AML supervision, not universal permission.
FSMA Part 4A authorization
Trigger: New regulated cryptoasset activities; Legal Basis: FSMA/2026 Regulations; Status: Applications open; Authority: FCA; Outcome and Limits: Specific permissions for upcoming regime.
Financial promotionsTrigger: Marketing qualifying cryptoassets to UK consumers; Legal Basis: FSMA section 21/Financial Promotion Order; Status: Current; Authority: FCA; Outcome and Limits: Lawful communications, not operating permission.

Which Activities Are Covered?

  1. Current MLR Scope
    Cryptoasset exchange services include fiat-to-crypto, crypto-to-crypto and arranging exchanges. Custodian wallet services include safeguarding customer assets or private keys
  2. Future FSMA Scope
    Trading platforms, dealing, arranging transactions, safeguarding and arranging safeguarding, qualifying stablecoin issuance in the UK, and arranging qualifying cryptoasset staking require activity-specific assessment
  3. Separate Analysis
    Payments, e-money, security tokens and token issuance may engage other rules. Public offers and trading admissions also have designated-activity requirements.
Having UK customers alone does not automatically trigger MLR registration. The business connection and marketing rules require separate analysis.

What Regulatory Support Will Gofaizen & Sherle Provide?

  1. Assessment & Structure

    • Route assessment and corporate structuring.
  2. Registration & Documentation

    • Application preparation, business plan and financial projections.
  3. Compliance Framework

    • AML/CTF procedures and governance framework.
  4. Operational Readiness

    • Owner and director forms, dossier submission and regulator communications.
    • FSMA readiness and financial promotions review within the agreed scope.

What Does the Service Cost?

Regulatory assessment

Price on quote

  • Included: Model and route review
  • Excluded or Separately Charged: Full application

Application package

Price on quote

  • Included: Documents and filing support;
  • Excluded or Separately Charged: Official and third-party costs;

Compliance support

Price on quote

  • Included: Agreed ongoing updates;
  • Excluded or Separately Charged:
  • Staffing, office and external audits;

Official charges: Included: Current MLR application; Excluded or Separately Charged: Annual supervision and FSMA fees; Category 6; Price: £11,260

FSMA charges depend on the application and permissions. The FCA fee schedule is separate from professional fees.

How Does the Process Work?

  1. Assess

    Gofaizen & Sherle maps activities, markets and UK connections using client information.

  2. Prepare

    The team develops documents. The client supplies evidence and approves operational arrangements.

  3. File

    Submit the applicable MLR application or separate FSMA application/permission variation. FCA controls assessment.

  4. Respond and Prepare for Launch.

    Resolve regulator questions and coordinate agreed operational work. Launch depends on required permissions and provider acceptance.

The client approves documents and remains accountable. FCA, banks and promotion approvers make their own decisions.

What Do We Need From You?

  • team cog

    Ownership & Management

    Shareholders, ultimate beneficial owners, directors and ownership chart.

  • chart board

    Business Model

    Business model, customer markets, UK operations and launch plans.

  • structure

    Transactions & Markets

    Transaction flows, custody arrangements and expected volumes.

  • fund

    Compliance & Financials

    Corporate records, funding evidence and financial information, existing policies, technology arrangements and previous applications

Our expertise

Why Gofaizen & Sherle?

We combine legal, regulatory and technical expertise to support businesses navigating complex regulatory requirements from initial assessment to implementation.

  1. Corporate structuring Company formation and cross-border business setup.
  2. Financial regulations Application preparation and regulator-facing documentation.
  3. Compliance & Governance AML/CTF frameworks and post-authorisation support.

What we handle

  • w assessment Project assessment
  • w structuring Structuring & Classification
  • w documentation Documentation
  • w implementation Implementation support
Mark Gofaizen

Mark Gofaizen

Senior Partner, Head of Consulting

mark@gofaizen-sherle.com
Maksim Gasanbekov

Maksim Gasanbekov

Partner, Head of Sales (Crypto and Blockchain)

maksim@gofaizen-sherle.com

How Long Does Preparation and Review Take?

  • Assessment and Preparation

    Estimated after document and readiness review.

  • MLR Review

    FCA has three months once it has all information needed to decide—not three months from initial submission.

  • FSMA Review

    Separate authorization assessment, affected by completeness, complexity and information requests.

  • Operational Setup

    Banking and other providers follow their own schedules.

Effective from 2026

How Does UK Cryptoasset Regulation Work?

The regulation of cryptoassets combines financial crime supervision, marketing restrictions and activity-specific financial services rules. The Financial Conduct Authority supervises relevant businesses, but each legal layer has its own scope. Existing rules still apply while the broader regime is being implemented. Security-token and payment activities can already require separate permissions, so the forthcoming changes do not postpone those obligations.

  1. MLR registration — Legal Basis: MLRs 2017, regulations 8, 9, 14A; Scope: Exchange and custody AML/CTF; Status: In force; Authority: FCA.
  2. Promotions — Legal Basis: FSMA section 21, Financial Promotion Order; Scope: Qualifying-cryptoasset communications; Status: In force; Authority: FCA.
  3. FSMA authorization/designated activities — Legal Basis: Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026; Scope: Broader activities, offers and admissions; Status: Main regime upcoming; Authority: FCA.

Current Regulatory Status

CurrentMLR registration and financial promotions obligations continue.
Applications Openthe FSMA application period runs September 30, 2026–February 28, 2027.
Upcomingfull commencement is expected October 25, 2027. Registration does not convert automatically.
Verificationcheck each firm’s status and permissions in the Financial Services Register.

What Ongoing Obligations Apply?

  1. MLRs: risk assessment, customer due diligence (CDD/KYC), sanctions controls, transaction monitoring, Travel Rule transfer information, suspicious activity reporting, records and staff training.
  2. Promotions: a lawful communication route, applicable risk warnings and customer safeguards.
  3. Future Permissions: applicable capital, governance, conduct, safeguarding and reporting rules under the new framework.

AML/CTF means anti-money laundering and counter-terrorist financing.

Which Taxes Need Assessment?

Corporation tax: Tax treatment of profits and gains depends on activity and structure

VAT: Treatment depends on the service, not simply use of cryptoassets

Payroll: Token remuneration can create tax and National Insurance obligations

Cross-border structure: Review tax residence and permanent establishment—a taxable business presence
HMRC’s Cryptoassets Manual explains business taxation. Assess the actual model individually.

What Creates Regulatory Risk?

  • Starting an in-scope business before registration.
  • Communicating unlawful promotions, including from overseas.
  • Describing registration as FCA endorsement.
  • Conducting activities outside required permissions.

Breaches can lead to enforcement, including criminal proceedings where applicable.

How Can Banking Preparation Help?

Banks, electronic money institutions (EMIs) and payment service providers (PSPs) assess their own onboarding risks.

  1. Ownership and source of funds — Gofaizen & Sherle Support, Where Agreed: Organize supporting evidence.
  2. Markets, counterparties and transaction flows — Gofaizen & Sherle Support, Where Agreed: Explain the operating model.
  3. Controls and on/off-ramp arrangements — Gofaizen & Sherle Support, Where Agreed: Prepare compliance documentation.

Registration or authorization does not guarantee account opening.

Which Alternatives Should You Compare?

Compare your target market first. CASP means crypto-asset service provider, while MSB/FMSB means money services business/foreign money services business.

MarketModelMain FitAccess and Limitation
United KingdomMLR/FSMA routesUK operationsNo MiCA passport.
European UnionMiCA CASPEU cryptoasset servicesCross-border notification, authorized scope
CanadaMSB/FMSBRelevant exchange/transfersSeparate securities assessment.
United StatesFederal/state frameworksUS customersMSB registration alone is insufficient

Frequently Asked Questions

Can an overseas firm use a promotions approver?

Yes, where the approver has the required permission and accepts the promotion. Approval addresses communications, not permission to operate. Gofaizen & Sherle can assess this route alongside your activities, existing status and plans under the new regime. Approver availability also affects practical feasibility.

Can we reuse documents from another jurisdiction?

Yes, as preparation inputs. They must accurately reflect this applicant and applicable requirements. Generic or outdated policies will need revision. Gofaizen & Sherle can review the existing package and identify what must change before filing and explain the preparation priorities. The review is applicant-specific.

Does an existing payment or e-money authorization cover crypto?

No. Under current rules, an existing authorization does not replace MLR registration for in-scope cryptoasset services. Gofaizen & Sherle can assess the additional application and whether your existing structure suits the planned services. Future FSMA permissions require separate analysis. Plan both workstreams together.

Client Testimonials

Trusted by Industry Leaders

Gofaizen & Sherle has successfully implemented all the tasks related to the settlement of legal part (company formation and VASP license application) of our exchange whitebit.com.

whitebit logo Vladimir Nosov CEO WhiteBIT
Axstron Finance Europe UAB;  Axstron Finance LLC Case study

Axstron Finance Europe UAB; Axstron Finance LLC

Services Provided: End-to-end support with company share transfers in Lithuania and the USA (Montana), corporate account opening, AML/KYC policy development, regulatory compliance for FNTT and FinCEN, MICA licensing advisory, HR recruitment for C-level and AML roles, and payroll accounting services.

Read case

Connect with our experts

Our experts will tell you how to do it as quickly and easily as possible.

Mark Gofaizen
Mark Gofaizen
Senior Partner, Head of Consulting
Maksim Gasanbekov
Maksim Gasanbekov
Partner, Head of Sales (Crypto and Blockchain)
Get in touch
Phone
Estonia +372 Estonia

    Connect with our experts

    Our experts will tell you how to do it as quickly and easily as possible.

    Estonia

      By clicking the button, I confirm that I have read the privacy policy and consent to the collection and processing of my personal data in accordance with the GDPR rules.

      Thank you

      Thank you for reaching us. Our team is working on your request, and we will contact you soon.

      Message not sent