Regulatory Licencing and Compliance Advisory for Cryptoasset and Digital Asset Firms
No jurisdiction issues a single crypto licence that covers every digital asset activity. Exchange, custody, transfer, brokerage, stablecoin issuance and staking are regulated differently, and often under separate authorisations, within the same regime.
Regulatory classification of tokens, services and business models
UK cryptoasset registration and the transition to the future UK regime
EU MiCA crypto-asset service provider authorisation
Canada, Australia, Singapore and Hong Kong digital asset requirements
Financial crime frameworks including the travel rule and blockchain analytics
Ongoing compliance, reporting and regulator engagement for digital asset firms
How we advise cryptoassets & digital assets
Regulatory Counsel advises cryptoasset and digital asset firms on classification first and applications second: what the activity is in regulatory terms, which regime captures it in each market served, and what the resulting compliance obligations look like in practice.
We work across the UK cryptoasset framework and its transition to full regulation, the EU markets in crypto-assets regime, Canadian, Australian, Singaporean and Hong Kong requirements, and the payments and e-money regimes that stablecoin and tokenised money models frequently engage.
Is there a single crypto licence?
No. Regulation attaches to activities, not to the word crypto. A firm running an exchange, holding customer assets in custody, arranging transactions for others and issuing a stablecoin may require different permissions for each of those activities, and different permissions again in each jurisdiction it serves.
This is why classification work comes before application work. Firms that begin with an application form frequently discover midway through that part of the business is outside the regime they applied under, or that a second permission is required before launch.
How are cryptoasset firms regulated in each priority market?
The regimes differ substantially in scope and maturity. The table sets out the primary supervisor and route in each of our priority markets.
| Jurisdiction | Regulator | Primary route |
|---|---|---|
| United Kingdom | FCA | Registration under the Money Laundering Regulations for cryptoasset businesses, with the regime moving toward full authorisation of cryptoasset activities under FSMA |
| European Union | National competent authorities under MiCA | Crypto-asset service provider authorisation, with separate requirements for asset-referenced and e-money tokens |
| Canada | FINTRAC, with provincial securities regulators | Registration as a money services business dealing in virtual currency, plus securities registration or undertakings where platforms trade crypto contracts |
| Australia | AUSTRAC, with ASIC for financial products | Digital currency exchange registration, and financial services licencing where the product is a regulated financial product |
| Singapore | MAS | Payment Services Act licence covering digital payment token services |
| Hong Kong | SFC, with other regulators by activity | Virtual asset trading platform licencing, and separate treatment for stablecoin issuance |
What is changing in the UK cryptoasset regime?
The UK is moving from an anti-money laundering registration regime for cryptoasset businesses to full regulation of cryptoasset activities under the Financial Services and Markets Act framework. Firms currently registered for money laundering purposes should plan for authorisation standards rather than registration standards.
The practical implication is that governance, prudential resources, custody arrangements, conduct standards and disclosure will be assessed in a way that AML registration never required. Firms that built only to registration standard will find the gap material, and the gap is best closed before an application window rather than during it.
What does MiCA require of crypto-asset service providers?
MiCA introduced a harmonised EU authorisation for crypto-asset service providers, covering activities including custody, operation of a trading platform, exchange, execution, placing, reception and transmission of orders, advice, portfolio management and transfer services, together with distinct regimes for asset-referenced tokens and e-money tokens.
Authorisation is granted by a national competent authority and, once obtained, supports cross-border provision within the EU. Firms should not assume that an existing national registration converts automatically; the substantive requirements around governance, custody segregation, prudential safeguards, complaints handling and disclosure are more demanding.
What financial crime controls do digital asset firms need?
Digital asset firms need the standard elements of a financial crime framework, calibrated to on-chain risk: an enterprise-wide risk assessment, customer due diligence, sanctions screening, transaction monitoring using blockchain analytics, travel rule compliance for transfers, and suspicious activity reporting.
- -Risk assessment covering asset types, chains, counterparties and geography
- -Blockchain analytics deployment, alert calibration and typology coverage
- -Travel rule solutions and counterparty due diligence for transfers
- -Sanctions screening covering wallet addresses as well as names
- -Governance and management information that shows the controls are working
How does Regulatory Counsel support digital asset firms?
We start with a regulatory classification of the business model, then build the licencing and compliance roadmap that follows from it: which permission in which market, in what sequence, with what control build required before submission.
Classify
Determine what each activity and token is in regulatory terms across the markets served.
Sequence
Prioritise the permissions that unlock revenue and identify those that can follow later.
Build
Governance, custody, financial crime and operational resilience controls to authorisation standard.
Apply
Prepare and manage the application and the regulator question process.
Operate
Ongoing compliance, reporting, monitoring and regulator engagement after approval.
Practitioner observations from cryptoassets & digital assets engagements
Classification errors are the expensive ones
The costly mistakes we see are not failed applications. They are firms that launched under one regime, grew, and then discovered that a feature added along the way brought the business inside another regime entirely.
Stablecoin models touch payments regulation
Tokenised money and stablecoin products frequently engage e-money or payments frameworks alongside cryptoasset rules. The analysis has to cover both, particularly where redemption at par is promised.
Custody is where supervisors concentrate
Segregation of client assets, key management, wallet architecture and what happens on insolvency attract detailed scrutiny in every maturing regime. Firms should expect to evidence these arrangements rather than describe them.
Licences and registrations for this sector
FCA Cryptoasset AML Registration
UK registration for cryptoasset businesses under the Money Laundering Regulations.
View licenceUK CASP Authorisation
The future UK authorisation regime for cryptoasset activities.
View licenceEU MiCA CASP Licence
Crypto-asset service provider authorisation under MiCA.
View licenceCanada MSB Registration
FINTRAC registration for dealing in virtual currency.
View licenceHow we support firms in this sector
Regulatory Licencing & Authorisation
Classification, licence selection and application management.
AML & Financial Crime
Digital asset financial crime frameworks and travel rule compliance.
Ongoing Compliance Support
Post-authorisation compliance, monitoring and reporting.
Compliance Advisory
Perimeter analysis and regulatory strategy for digital asset models.
Classify your digital asset activities before you apply
Tell us your business model, the markets you serve and the permissions you hold. We will tell you what is actually in scope and what the credible route looks like.
Get Expert Advice
Related insights
FCA Cryptoasset Financial Promotions Rules: What Every UK Crypto Firm Must Know
The FCA's cryptoasset financial promotions regime under PS23/6 - mandatory risk warnings, approval categories, common violations and enforcement consequences.
CryptoassetsUK Stablecoin Regulation in 2026: What Issuers and Payment Firms Must Prepare For
The FCA has opened its regulatory sandbox for stablecoin testing in 2026. What issuers and payment firms need to know about reserve backing, authorisation and compliance.
CryptoassetsFrom MLR to FSMA: How to Transition Your Cryptoasset Business to Full FCA Authorisation
The transition from MLR registration to FSMA authorisation is the biggest regulatory shift for UK crypto firms. Practical guidance on timeline, capital and conduct requirements.
Frequently asked questions
No. UK registration has no EU effect. Providing crypto-asset services to customers in the European Union generally requires MiCA authorisation from a national competent authority in an EU member state.
Registration under the Money Laundering Regulations assesses whether a firm has adequate financial crime controls and fit and proper individuals. Authorisation assesses the whole business: governance, prudential resources, custody, conduct and operational resilience. The evidential burden is considerably higher.
It needs to assess every market where it has customers or actively markets. Some jurisdictions regulate on the basis of establishment, others on the basis of services directed at local persons. Passive access is not always a defence.
It depends on the token and the jurisdiction. In the EU, e-money tokens and asset-referenced tokens have distinct treatment under MiCA. In the UK, the analysis can engage the e-money and payments framework alongside the cryptoasset regime. Firms should classify the token before designing the product.
It can. Depending on how a staking service is structured, it may be treated as a distinct regulated service, may raise questions about custody of client assets, or may engage collective investment or financial product rules. The structure of the arrangement drives the answer.
The travel rule requires originating and beneficiary information to accompany cryptoasset transfers, with obligations on both sending and receiving firms. Implementation involves solution selection, counterparty due diligence, handling transfers to unhosted wallets and a documented approach to non-compliant counterparties.
By closing the gap between registration standard and authorisation standard: governance and senior management accountability, prudential resources, custody and client asset arrangements, conduct and disclosure, operational resilience, and evidence that controls operate rather than merely exist.
Primary regulatory sources
This page summarises regulatory requirements for orientation. It is not legal advice. The primary sources below govern.