Crypto Law Profile

FCA Cryptoasset Business Registration Regime under the UK MLRs

UK cryptoasset exchange and custodian wallet providers carrying on business in the UK must register with the FCA before starting in-scope services and meet MLR AML/CTF duties. The regime remains in force during the transition to...

United Kingdom Effective Regulation Jan 10, 2020

At a glance

Status In force since 10 January 2020; amendments and the FSMA transition phase in through October 2027.
Primary regulator The FCA registers and supervises in-scope UK cryptoasset businesses for AML/CTF purposes.
Covered businesses Cryptoasset exchange providers and custodian wallet providers carrying on business in the UK.
Travel Rule Part 7A transfer-information duties have applied to cryptoasset transfers since 1 September 2023.

Overview

The FCA Cryptoasset Business Registration Regime is the United Kingdom’s in-force anti-money laundering and counter-terrorist financing framework for certain cryptoasset businesses under the Money Laundering Regulations 2017, as amended. The crypto-specific gateway has applied since 10 January 2020. As of 19 June 2026, an in-scope cryptoasset exchange provider or custodian wallet provider carrying on business in the UK generally must be registered with the Financial Conduct Authority before beginning those services. A separate FCA authorisation or registration for another financial service does not replace the MLR registration.

Registration is limited to AML/CTF supervision. The FCA states that it is a legal requirement, not an endorsement or recommendation of the business, and it should not be presented as equivalent to full authorisation under the Financial Services and Markets Act 2000.

Who the FCA cryptoasset registration regime covers

The exchange-provider definition includes exchanging cryptoassets for money, money for cryptoassets or one cryptoasset for another; arranging those exchanges; and operating cryptoasset ATMs. It can also capture creators or issuers when they provide those services. The custodian-wallet definition covers safeguarding customer cryptoassets, or safeguarding and administering private cryptographic keys used to hold, store or transfer cryptoassets.

The territorial test focuses on business carried on in the UK. A UK office, head office or crypto ATM may indicate UK activity. The FCA says that merely serving a UK client, without a UK office or other UK activity, does not automatically mean the business is carried on in the UK. The separate financial-promotions regime may nevertheless apply to marketing directed at UK consumers regardless of where the firm is based.

Core registration and AML/CTF requirements

The FCA assesses the applicant, relevant officers, managers and beneficial owners under the MLR fit-and-proper test. The statutory framework permits refusal where requirements are not met or information is materially false or misleading, and gives the FCA three months to determine a complete cryptoasset registration application before any representations process.

Registered firms remain subject to ongoing, risk-based obligations rather than a one-time filing. Expected controls include a business-wide risk assessment, customer risk assessments, customer and enhanced due diligence, sanctions and politically exposed person screening, transaction monitoring, training, suspicious activity reporting, record-keeping, outsourcing oversight and an appointed money laundering reporting officer. The FCA expects systems and policies to be tailored to the firm’s business model and to address both on-chain and off-chain activity where relevant.

Travel Rule and 2026 MLR amendments

Since 1 September 2023, Part 7A of the MLRs has imposed cryptoasset transfer-information duties commonly called the Travel Rule. Depending on the transfer, originator and beneficiary names, account numbers or unique transaction identifiers, and additional identifying information may need to accompany the transfer. The framework also addresses verification, missing information, intermediaries, unhosted wallets, retention and disclosure to law enforcement.

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were made on 9 June 2026. Most provisions commence on 30 June 2026. Crypto-specific enhanced due diligence for certain correspondent relationships starts on 1 February 2027, while elements of the revised change-in-control schedule take effect in stages through 25 October 2027.

Transition to the UK FSMA crypto regime

MLR registration remains operative during the transition to the broader FSMA cryptoasset regime. The FCA’s FSMA application window runs from 30 September 2026 to 28 February 2027, and the new regime is scheduled to start on 25 October 2027. MLR registration does not convert into, or guarantee, FSMA authorisation.

On full commencement, the 2026 Cryptoassets Regulations restructure the MLR register so that authorised cryptoasset firms and specified-investment cryptoasset firms are excluded from that register and instead follow a notification route. The MLR gateway will continue for businesses that remain within its scope and do not fall within those exclusions. The change is therefore a transition and reconfiguration of the AML registration framework, not a blanket repeal of the MLR obligations.

This profile is a general legal-reference summary and does not constitute legal advice.

Key provisions

Registration before trading

In-scope cryptoasset businesses carrying on business in the UK must obtain FCA registration before beginning covered services.

Licensing & Registration Jan 10, 2020 Source

Cryptoasset exchange-provider scope

Covers exchanging or arranging exchanges between cryptoassets and money, crypto-to-crypto exchange, and operating crypto ATMs.

Licensing & Registration Jan 10, 2020 Source

Custodian wallet-provider scope

Covers safeguarding customer cryptoassets, or safeguarding and administering private cryptographic keys used to hold, store or transfer cryptoassets.

Custody Jan 10, 2020 Source

Fit-and-proper assessment

Specified owners, officers and managers must be fit and proper; the MLRs also provide refusal, suspension and cancellation powers.

Licensing & Registration Jan 10, 2020 Source

Risk-based AML/CTF controls

Firms must maintain risk assessments, policies, controls and procedures covering due diligence, monitoring, training, suspicious activity reporting and related risks.

AML/CFT Jan 10, 2020 Source

Cryptoasset Travel Rule

Part 7A requires specified originator and beneficiary information for certain transfers, with verification, retention and missing-information duties.

Payments Sep 1, 2023 Source

Change in control

FCA notification and approval rules apply to acquisitions or increases in control; SI 2026/621 begins aligning thresholds with the FSMA framework.

Licensing & Registration Source

Transition to FSMA authorisation

MLR registration does not convert into FSMA authorisation. The new regulated cryptoasset activities move to the FSMA regime on 25 October 2027.

Regulatory perimeter Oct 25, 2027 Source

Timeline

  1. Money Laundering Regulations 2017 made

    The foundational UK MLRs were made, creating the wider AML/CTF framework later extended to cryptoasset businesses.

    Enacted Source
  2. Cryptoasset amendments made

    SI 2019/1511 added cryptoasset exchange providers, custodian wallet providers and the FCA registration gateway.

    Enacted Source
  3. FCA cryptoasset registration regime begins

    The cryptoasset-specific registration and supervision provisions came into force.

    In force Source
  4. Travel Rule amendment made

    SI 2022/860 inserted Part 7A transfer-information duties and strengthened change-in-control rules.

    Enacted Source
  5. Cryptoasset Travel Rule begins

    Part 7A cryptoasset transfer-information requirements came into force.

    In force Source
  6. FSMA Cryptoassets Regulations made

    SI 2026/102 established the forthcoming FSMA cryptoasset regime and its MLR transition provisions.

    Enacted Source
  7. 2026 MLR amendments made

    SI 2026/621 made targeted MLR changes, including crypto change-in-control alignment and correspondent-relationship EDD.

    Enacted Source

Who it affects

Actors

Financial Conduct Authority, HM Treasury

Asset classes

Cryptoassets

Official sources

Editorial note

This profile treats the FCA registration framework as a regulatory regime created by amendments to the 2017 MLRs, rather than as a standalone instrument. MLR registration is limited to AML/CTF supervision; it is not FCA endorsement or FSMA authorisation.

SI 2026/621 was made on 9 June 2026. Most provisions commence on 30 June 2026; cryptoasset correspondent-relationship EDD commences on 1 February 2027.