Crypto ATM / kiosk operator in United Kingdom

FCA — MLR registration and AML/CTF supervision of cryptoasset businesses (since 10 January 2020), supervision of cryptoasset financial promotions (since 8 October 2023), and authorisation, conduct and prudential regulation under SI 2026/102 from 25 October 2027. Of 393 MLR applications determined since January 2020, 68 were registered, 46 rejected, 265 withdrawn and 14 refused (as at 1 October 2026).

Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692), as amended by SI 2019/1511 with effect from 10 January 2020 — AML/CTF registration and supervision of cryptoasset exchange providers and custodian wallet providers (regs 14A, 56, 58A); travel rule in Part 7A from 1 September 2023 (SI 2022/860).

Financial Services and Markets Act 2000, as amended by FSMA 2023 s.69 (in force 29 August 2023) — s.22 extended so regulated activities may relate to cryptoassets and s.417 given a cryptoasset definition; the regulated activities themselves are created by SI 2026/102 from 25 October 2027, and the crypto financial-promotions regime came from SI 2023/612 (7 October 2023).

Financial Services and Markets Act 2000 (Financial Promotion) (Amendment) Order 2023 (SI 2023/612, made 7 June 2023, in force for all purposes 7 October 2023) — adds "qualifying cryptoasset" as a controlled investment and creates the art 73ZA exemption for MLR-registered firms' own promotions; the FCA classifies qualifying cryptoassets as restricted mass market investments in COBS 4.12A and has applied the regime since 8 October 2023.

FCA MLR registration is required for cryptoasset exchange providers and custodian wallet providers. Since January 2020 the FCA has received 427 applications and determined 393: 68 registered (17%), 46 rejected (12%), 265 withdrawn (67%) and 14 refused (4%) as at 1 October 2026. The FSMA-based regime under SI 2026/102 (trading platforms, dealing, arranging, safeguarding, staking, qualifying stablecoin issuance) starts 25 October 2027.

EXCHANGE: MLR registration plus the financial-promotions rules in COBS 4.12A (prescribed risk warnings, fair clear and not misleading, incentive ban). The retail ban on cryptoasset derivatives (CFDs, futures, options) has applied since 6 January 2021 (PS20/10) and remains; retail access to crypto exchange-traded notes traded on an FCA-approved UK exchange reopened on 8 October 2025.

The FCA is the UK conduct regulator for financial services and the regulator for cryptoassets: AML/CTF supervisor of cryptoasset businesses since 10 January 2020, supervisor of the cryptoasset financial-promotions regime since 8 October 2023, and from 25 October 2027 the authorising, conduct and prudential regulator for the activities in SI 2026/102.

The FCA registers and supervises cryptoasset exchange providers and custodian wallet providers for AML/CTF under the Money Laundering Regulations 2017 (regs 14A and 56), a regime in force since 10 January 2020 (SI 2019/1511).

MLR registration is required for cryptoasset exchange and custodian wallet services provided by way of business in the UK, and registration must be obtained before any in-scope service starts; the presence of a crypto ATM in the UK is treated as business carried on in the UK.

Cryptoasset exchange providers and custodian wallet providers have been "relevant firms" under every UK sanctions regime since 30 August 2022 (SI 2022/818) and must freeze funds and economic resources of designated persons, not make funds available to them, and report to OFSI any designated-person holdings and suspected breaches; OFSI published "Sanctions compliance in the Cryptoassets sector: Threat Assessment" on 21 July 2025 setting out the sector-specific evasion risks it expects firms to control.

UK sanctions are made under the Sanctions and Anti-Money Laundering Act 2018 s.1 either to comply with UN Security Council obligations or for autonomous UK purposes such as human rights, national security and foreign policy, and are administered by OFSI within HM Treasury; they bind all persons in the UK and UK persons worldwide (s.21), and OFSI guidance treats cryptoassets as covered by the asset-freeze definitions. The UK regime contains no "secondary sanctions" instrument; US OFAC measures are not part of UK law.

Cryptoasset exchange providers and custodian wallet providers registered with the FCA under the Money Laundering Regulations 2017 reg 14A have been "relevant firms" under every UK sanctions regime since 30 August 2022 (SI 2022/818) and must screen for designated persons and report to OFSI; the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102) bring safeguarding of qualifying cryptoassets and other cryptoasset activities into FSMA authorisation on 25 October 2027, with the FCA application window running 30 September 2026 to 28 February 2027 and no automatic conversion of MLR registrations.

UK financial sanctions prohibitions bind all persons within the UK and United Kingdom persons for conduct anywhere in the world (SAMLA 2018 s.21), so a UK cryptoasset firm must apply asset-freeze and OFSI reporting obligations to transactions it conducts abroad, including in markets where cryptoassets are otherwise unregulated; the obligations attach to designated persons on the UK Sanctions List rather than to whole jurisdictions.

Prohibited dealings with prescribed countries like Russia (post-2022 embargoes), North Korea, Iran, or Syria-linked entities; crypto transfers to/from these are high-risk and often blocked.

UK sanctions offences created under SAMLA 2018 regulations carry a statutory maximum of 10 years imprisonment on indictment (SAMLA s.17(5)); OFSI may impose civil monetary penalties under the Policing and Crime Act 2017 s.146 of up to the greater of £1,000,000 and 50% of the estimated value of the funds or economic resources involved; carrying on unauthorised regulated activity (FSMA 2000 s.23) and contravening the Money Laundering Regulations 2017 (reg 86) each carry up to two years imprisonment and a fine on indictment.

FCA cryptoasset enforcement to date comprises three actions: CB Payments Ltd (Coinbase group) fined £3,503,546 on 25 July 2024 under the Electronic Money Regulations 2011 after onboarding 13,416 high-risk customers in breach of a voluntary requirement; Olumide Osunkoya sentenced to four years at Southwark Crown Court on 28 February 2025 for running an unregistered crypto ATM network worth over £2.5m, the first UK criminal conviction for unregistered cryptoasset activity; and legal proceedings begun against HTX (formerly Huobi) on 10 February 2026 for illegal financial promotions to UK consumers. Firms that do not apply for FSMA authorisation in the 30 September 2026 to 28 February 2027 window must run off UK cryptoasset business before the regime commences on 25 October 2027 or breach the FSMA s.19 general prohibition.