An international institutional digital assets firm offering stablecoin-based cross-border brokerage services engaged Lysis Advisory to support its UK FCA registration under the Money Laundering Regulations (MLRs). The firm operates a multi-jurisdictional, technology-driven brokerage model providing access to deep cryptoasset liquidity for corporate and professional clients. Lysis was selected due to its strong track record of successful FCA applications and its ability to deliver a tailored regulatory framework aligned with current FCA expectations and adaptable to the upcoming FSMA-style regime.
Crypto & Digital Assets
The client is an international institutional digital assets firm providing stablecoin‑enabled cross‑border brokerage services to corporate and professional counterparties. The firm operates an institutional brokerage model, offering access to deep liquidity across major cryptoassets and stablecoins. Services are delivered through proprietary technology and regulated entities in multiple jurisdictions.
The client engaged Lysis Advisory to support its UK Financial Conduct Authority (FCA) registration under the Money Laundering Regulations (MLRs), requiring a UK‑specificregulatory framework aligned to FCA expectations for cryptoasset firms and capable of transitioning to the UK’s forthcoming FSMA‑style regime.
Lysis was chosen to support this work because of our 100% success rate for our digital assets applications to the FCA and structured yetflexible delivery model.
The challenge was to develop a UK-specific regulatory framework that met strict FCA expectations under the MLRs, while also being flexible enough to adapt to the UK’s upcoming FSMA-style regime for cryptoasset firms.
Scope of Work
The scope of work was the full end-to-end application process and all necessary documents and artefacts including:
• Business Model, Strategy & Regulatory Business Plan
• Governance, Senior Management & Oversight
• Financial Crime: AML, CTF & Sanctions
• Business Wide Risk Assessment (BWRA) – [link to BWRA service on website]
• Financial Plan & Capital Model
• Wind Down Planning
• Information Security & Operational Resilience
Lysis also supported the application management & FCA engagement.
1. Business Model, Strategy & Regulatory Business Plan
Lysis worked with the client to author and iterate a comprehensive UK FCA Regulatory Business Plan, clearly articulating:
• The UK business rationale and institutional only target market
• The operating and delivery model, including cross border flows and use of stablecoins
• Governance, senior management roles, and UK substance
• Alignment to current MLR requirements and anticipated future UK crypto regulation
The plan was structured explicitly to meet FCA expectations on clarity, credibility and internal consistency and cross referenced to all supporting governance, risk, and control documents.
2. Governance, Senior Management & Oversight
Lysis worked with the client to design and document a proportionate UK governance framework, including:
• Board and committee structures
• Clear allocation of responsibilities to senior managers
• MLRO oversight and escalation mechanisms
• Regulatory reporting and management information flows
This ensured demonstrable accountability, effective challenge and FCA aligned decision making for a UK cryptoasset firm.
3. Financial Crime: AML, CTF & Sanctions
Lysis conducted a detailed review and enhancement of the client’s AML/CTF framework, assessing governance, policies, procedures and controls against FCA expectations for digital assets firms. Deliverables included:
• A formal critique of existing AML frameworks and controls vis-à-vis UK requirements
• Enhancement of customer risk assessment methodologies
• Review of onboarding, transaction monitoring, sanctions screening, and controls testing
• Clear mapping of risks to controls and senior ownership
The outcome was a robust, FCA defensible AML framework tailored to the firm’s institutional crypto business model.
4. Business Wide Risk Assessment (BWRA)
Lysis supported the development of a UK specific Business Wide Risk Assessment, identifying and articulating inherent and residual risks and controls across:
• Financial crime
• Operational and technology risks
• Regulatory and cross border risks
The BWRA was explicitly linked to the firm’s governance arrangements, risk appetite and control environment, in line with FCA expectations.
5. Financial Plan & Capital Model
Lysis supported the preparation and structuring of the UK Financial Plan, ensuring it:
• Reflected the UK business model and growth assumptions
• Demonstrated adequate funding and financial sustainability
• Clearly articulated cost bases, revenues and resource requirements
• Was consistent with the Regulatory Business Plan and governance model
The financial plan was positioned to evidence prudence, realism and resilience, addressing FCA concerns around under capitalisation and operational fragility in cryptoasset firms.
6. Wind Down Planning
Recognising the FCA’s heightened focus on orderly wind down for cryptoasset firms, Lysis documented a UK Wind Down Plan, covering:
• Credible wind down triggers and governance
• Financial and operational assumptions
• Client asset protection and communications
• Orderly cessation of regulated activities
The plan demonstrated that the firm could exit the UK market in a controlled manner without harm to clients, markets, or financial crime objectives.
7. Information Security & Operational Resilience
Lysis assessed the firm’s information security and operational resilience arrangements, including custody controls, access management, incident response and continuity planning, ensuring the FCA application evidenced secure and resilient operations appropriate for institutional digital assets activity.
8. Application Management & FCA Engagement
Lysis managed the end to end application programme through structured project planning, document coordination, internal workshops and preparation for FCA engagement, ensuring a coherent, internally consistent, and regulator ready submission.
The engagement delivered a fully FCA‑aligned application pack, combining a credible business strategy, robust governance, effective financial crime controls, a realistic financial plan and a defensible wind‑down strategy. The client was positioned to submit a high‑quality FCA application and to adapt efficiently to the UK’s evolving crypto regulatory regime.
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