UK FCA Q&As on interaction between the MLRs 2017 and the new UK crypto regime

The UK Financial Conduct Authority (FCA) has published Q&A responses from its 2026 webinar on the UK anti money laundering (AML) framework for cryptoasset firms. They clarify how the current Money Laundering Regulations 2017 (MLRs) will operate alongside the forthcoming cryptoasset regime under the Financial Services and Markets Act 2000 (Cryptoassets Regulations) 2026, which commences on 25 October 2027. Topics addressed include:

• Applications under the Financial Services and Markets Act 2000 (FSMA) regime. 
  • MLR registration will remain the route for firms providing in scope cryptoasset services until the new regime commences, but firms will need to obtain FSMA authorisation to continue operating under the new regime, with no automatic conversion.
  • Current FSMA authorised firms must apply to vary their permissions if they wish to undertake the new cryptoasset regulated activities when the regime commences.
  • Applications for the new regime will open on 30 September until 28 February 2027. Firms should consider the impact of when they submit their application. Firms are encouraged to prioritise securing FSMA authorisation over MLR-registration (with more guidance set out in an earlier webpage) and undertake early gap analyses against threshold conditions and proposed rules.
• Authorisation expectations and application quality that:
  • FSMA authorisation assessments will be broader than MLR-registration, covering governance, systems and controls and financial crime readiness among other areas. Firms are encouraged to engage with the FCA's financial crime guidance and use its pre-application support service to ensure an efficient assessment.

The FCA also covers expectations in the areas of AML governance, MLRO and senior management arrangements, crypto‑specific risk assessments and typologies, transaction monitoring and oversight, the travel rule, sanctions and financial crime controls, operational resilience, and cross‑border compliance.

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