Lysis enabled a major US crypto exchange to achieve UK FCA registration through full regulatory transformation, governance design, and compliance support.
Payment Services & Card/ Merchant Acquirers
A large US-based cryptocurrency exchange seeking UK market entry through FCA cryptoasset registration. The client also aimed to secure authorisation for its UK-based card subsidiary as an FCA-regulated Electronic Money Institution (EMI).
While the client had mature regulatory operations aligned with US requirements, its frameworks and controls did not meet the specific standards expected by the UK Financial Conduct Authority (FCA). To successfully secure UK authorisations, the client required a comprehensive regulatory transformation across governance, financial crime, risk and operational domains.
Lysis provided end-to-end regulatory advisory and delivery support, including:
• Conducted a maturity assessment of the client’s US-centric regulatory framework against FCA expectations
• Led the preparation and submission of the full FCA cryptoasset registration and EMI authorisation applications
• Performed an Enterprise Wide Risk Assessment (EWRA) and a comprehensive Client Monies review across both entities
• Established robust UK/EU governance structures, including a European risk committee and supporting documentation
• Designed a skills and capacity model to scale the UK Risk and Compliance functions appropriately
• Provided an interim Deputy MLRO to support early operations
• Developed and embedded a full financial crime framework, including all related policies and procedures
• Deployed a large regulatory operations team to remediate legacy customer-level AML issues
• Delivered ongoing compliance advisory support to ensure sustainability post-registration
• Achieved UK FCA cryptoasset registration and progressed EMI authorisation for the client’s card subsidiary
• Established a compliant and scalable governance and risk framework for UK operations
• Enabled long-term UK market access and enhanced global regulatory credibility
• Strengthened operational readiness to support future regulatory change and business expansion
One of our client's banks has flagged areas of our client's Ant-Money Laundering (AML) Governance and Compliance operation as a potential cause for concern. Our client asked Lysis to perform an independent review for them to establish if anything was genuinely wrong.
A significant UK and US corporate bank with questions around the quality of the firm’s AML capabilities and customer files
Our client wished to outsource the Client On-Boarding and AML Operations for its merchant acquiring business in Europe, replacing their current major global outsourcing partner.
