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.
AuthorityFinancial Conduct Authority (FCA)
Current RouteMLR registration for in-scope business
Upcoming RouteFSMA Part 4A permission, with applications open
ApplicationSubmission through FCA Connect
CostProfessional fees quoted separately from official charges
TimelinePreparation assessed separately from regulator review
ResultApplication dossier and response support
CapitalAssess funding against the selected permissions
Local Presence and CompanyStructure and operational requirements depend on the route
Banking SupportSeparately agreed scope
Which Cryptoasset Businesses Does This Fit?
May fit
Exchange, custody and brokerage providers planning substantive UK operations
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 License
When It Applies
FCA cryptoasset registration
Trigger: 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 promotions
Trigger: 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?
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
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
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?
01
Assessment & Structure
Route assessment and corporate structuring.
02
Registration & Documentation
Application preparation, business plan and financial projections.
03
Compliance Framework
AML/CTF procedures and governance framework.
04
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?
Step1
Assess
Gofaizen & Sherle maps activities, markets and UK connections using client information.
Step2
Prepare
The team develops documents. The client supplies evidence and approves operational arrangements.
Step3
File
Submit the applicable MLR application or separate FSMA application/permission variation. FCA controls assessment.
Step4
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?
Ownership & Management
Shareholders, ultimate beneficial owners, directors and ownership chart.
Business Model
Business model, customer markets, UK operations and launch plans.
Transactions & Markets
Transaction flows, custody arrangements and expected volumes.
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.
01Corporate structuringCompany formation and cross-border business setup.
02Financial regulationsApplication preparation and regulator-facing documentation.
03Compliance & GovernanceAML/CTF frameworks and post-authorisation support.
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.
LawFSMACryptoassets Regs
Effective from2026
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.
MLR registration and financial promotions obligations continue.
Applications Open
the FSMA application period runs September 30, 2026–February 28, 2027.
Upcoming
full commencement is expected October 25, 2027. Registration does not convert automatically.
Verification
check each firm’s status and permissions in the Financial Services Register.
What Ongoing Obligations Apply?
MLRs: risk assessment, customer due diligence (CDD/KYC), sanctions controls, transaction monitoring, Travel Rule transfer information, suspicious activity reporting, records and staff training.
Promotions: a lawful communication route, applicable risk warnings and customer safeguards.
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.
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.
Ownership and source of funds — Gofaizen & Sherle Support, Where Agreed: Organize supporting evidence.
Markets, counterparties and transaction flows — Gofaizen & Sherle Support, Where Agreed: Explain the operating model.
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.
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.
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.
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.
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