Consulting & Advisory

Conducted a Maturity Assessment/assessed the firm's Financial Crime Framework

Although the client is based in the US, they have European subsidiaries which include the UK and therefore required Financial Conduct Authority (FCA) registration. In order to obtain registration as a crypto asset firm in the U.K. they had to comply with specific FCA requirements.

The Client

A new to market crypto asset business domiciled in the US.

The Challenge

A review was required to assess whether the client’s financial crime framework was fit for purpose and aligned with the Financial Conduct Authority (FCA) regulatory requirements to register and operate as a crypto asset firm in the UK. This called for a maturity assessment to depict the current state of a firm’s controls and their level of regulatory compliance. It also benchmarks and tests against a firm’s existing standards, global standards, and most importantly, against regulatory expectations.

The Solution

Lysis reviewed the anti-money laundering (AML) framework of the firm to determine if the policies were applied correctly in the operational environment and made recommendations, based on identified gaps, for uplifts and updates to the existing policies. Some of the reviewed policies included the AML policy, the Group Compliance Monitoring Policy and Procedures, the Anti-Bribery & Corruption Policy, sanctions policy etc. One of the main recommendations included the implementation of global standards by which the UK and European policies are based on the documents produced at a group level and tailored to meet the local UK requirements while still meeting the global minimum standards.


Lysis provided the client with a detailed report that contained the findings of the review. They conducted a gap analysis against the firm’s current approach to AML and current regulatory requirements which allowed the firm to gain a detailed and independent understanding of its AML governance framework and FCA requirements to register and operate in the UK. Consequently, with the support from Lysis, the crypto asset firm obtained full registration with the FCA to operate as a crypto asset firm in the UK.

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