FCA crypto/asset custody regulatory advisory

FCA crypto & asset custody regulatory advisory services

The governing landscape for cryptoassets in the UK has actually progressed quickly as the Financial Conduct Authority (FCA) strengthens requirements around custody, protecting and functional resilience. Services supplying guardianship, budget infrastructure, token solutions or crypto-related monetary products have to currently navigate increasingly complicated policies. Our advisory service helps firms understand their regulatory perimeter, prepare for FCA authorisation, design compliant custody frameworks and manage ongoing obligations. We also ensure alignment with developments in UK crypto regulation, allowing clients to anticipate obligations early.

Understanding FCA regulatory perimeter for crypto/asset custody

Before building custody solutions or applying for permissions, firms must identify whether their business model falls within the FCA’s regulatory remit. Because UK law distinguishes between regulated activities, unregulated tokens and AML-supervised businesses, accurate scoping is essential. We analyse your business model, custody design and token structure to clarify your regulatory exposure.

Key areas we examine include:

• Whether custody arrangements constitute a regulated “safeguarding” function under the FCA’s Client Asset Sourcebook (CASS).
• Whether your token type falls under e-money, regulated security tokens or unregulated exchange tokens as part of broader UK crypto asset regulation requirements.
• Whether your operational model triggers permissions related to safeguarding, arranging custody, investment activities or payment services.
• AML and counter-terrorist financing duties under Money Laundering Regulations.

After completing this assessment, we outline the regulatory perimeter and required steps for compliance. We also help custody providers understand how crypto exchange UK regulation may impact wallet services or trading functionality. Finally, we highlight where upcoming reforms—such as measures tied to UK treasury crypto regulation—could influence operational planning.

Designing FCA-compliant crypto custody, safeguarding & operational controls

Establishing a compliant custody model requires strong governance, documented safeguarding processes and secure operational design. We assist firms in creating frameworks that align technical, legal and organisational requirements. Our support ensures that client assets remain protected, segregated and transparently managed.

We support clients with the following aspects:

1. Implementing segregation of client and firm assets, including wallet-level controls.
2. Drafting safeguarding procedures aligned with CASS and FCA expectations, consistent with evolving UK crypto regulation standards.
3. Designing governance structures, accountability maps and senior management responsibilities.
4. Establishing resilience, incident-response procedures and recovery planning.
5. Drafting custody agreements, disclosures and consumer-protection documentation.

Once your framework is in place, we conduct a compliance gap analysis and identify improvements. Our guidance helps firms prepare for internal audits and supervisory reviews under crypto regulation in UK. With this support, providers can demonstrate strong operational and governance standards throughout their custody lifecycle.

FCA authorisation, registration support & ongoing compliance 

FCA authorisation requires detailed documentation, risk assessments and evidence of robust internal controls. We guide firms through the entire process, including business plans, governance structures, safeguarding narratives and AML frameworks. Our work often includes evaluating how UK crypto regulation framework applies to the firm’s custody operations. Post-authorisation, we support ongoing obligations, regulatory reporting, change-in-control procedures, board briefings and thematic review preparation. For businesses subject to crypto exchange regulation UK, we assist with continuous compliance and updates as regulatory expectations evolve.