Guides · UK · Chapter 02
UK crypto dual track
MLR registration today. FSMA cryptoasset authorisation on the incoming track. One seat, two nouns — and decks that blur them.
In this chapter, read in order
- What this is
- Two tracks
- Timeline
- Change of control
- Official sources (top → bottom)
What this is
UK cryptoasset firms sit on a transition. “FCA registered” is usually the AML registration story. Product authorisation under the new FSMA crypto regime is a separate filing — not an automatic upgrade.
Related: Crypto licence types · MiCA guide (different seat) · Glossary
Two tracks
| Regime | What it is | What it is not |
|---|---|---|
| MLR registration | Mandatory AML/CTF registration to conduct in-scope cryptoasset business in the UK | A prudential licence; proof of FSMA product permissions; a recommendation stamp |
| FSMA authorisation (incoming) | Product / regulated-activity authorisation under the new cryptoasset regime | Automatic upgrade from MLR registration |
Working timeline
- MLR change-in-control amendments (watch FCA materials for live detail)
- Applications for FSMA cryptoasset authorisation expected to open
- New regime expected to apply — plan migration from MLR-only status
Treat dates as planning anchors. Confirm on the live FCA pages before you condition a deal or an application calendar.
Change of control
- MLR-registered firms: prior FCA approval for control changes — completing without approval can be a criminal offence under the MLR track
- Firms that also hold FSMA permissions: Part XII can sit alongside crypto CoC — map both tracks
- Buyer DD: controllers, source of funds, business plan for material stakes, live register export
Buyer / applicant traps
- “FCA registered” = licensed exchange Often means MLR registration only. Read the permission string.
- Assuming MLR upgrades itself FSMA authorisation is a separate application and readiness project.
- Closing CoC on hope Prior approval is not a post-completion tidy-up.
Official sources
- Legislation Money Laundering Regulations 2017 Statutory frame for cryptoasset registration (as amended).
- AML register Cryptoassets AML/CTF regime
- Incoming FSMA New regime for cryptoasset regulation
- Crypto CoC Cryptoasset firms — change in control
- FSMA CoC Change in control (Part XII)
- Register FCA Financial Services Register
- Publications FCA publications Filter cryptoasset consultations and policy statements.
- Policy HM Treasury — cryptoasset publications
- Library Full UK filing library · UK payments (PI/EMI)
Not legal advice. Compare MiCA when the group also claims EU rights. SKU-01 for buy-side working tables.