Centralized exchange in United Kingdom
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is conditionally permitted in United Kingdom with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- FCA registration under Money Laundering Regulations 2017 (amended) — mandatory for all cryptoasset exchange providers and custodian wallet providers operating in the UK
- Customer due diligence (CDD) and ongoing monitoring under MLR 2017
- Travel Rule (GBP 0 threshold) — must transmit originator and beneficiary info on all crypto transfers with no de minimis exemption
- Sanctions screening — immediately freeze and restrict assets of designated persons, report to OFSI; comply with OFSI-implemented sanctions (UN/EU-aligned but UK-specific)
- Prohibited dealings with prescribed countries (Russia post-2022 embargoes, North Korea, Iran, Syria) — crypto transfers to/from these are high-risk and often blocked
- Financial promotions compliance — crypto classified as restricted mass-market investments, risk warnings mandatory, no misleading promotions, incentive restrictions
- Transaction monitoring and suspicious activity reporting (SAR) to FCA/NCA
- Record-keeping obligations under MLR 2017
- Unlimited fines, asset seizures, or imprisonment (7-10 years) for non-compliance under Sanctions and Anti-Money Laundering Act 2018 and FSMA
Key Restrictions
- Must register with FCA as a cryptoasset business — ~85% rejection/withdrawal rate, only ~40 firms registered
- Local legal entity required — cryptoasset businesses operating in the UK must register with FCA regardless of where customers are
- Crypto derivatives banned for retail customers since 2021
- No EU passporting post-Brexit — separate UK authorization required
- Financial promotions rules apply: crypto is a restricted mass-market investment, risk warnings mandatory, no misleading promotions, incentive restrictions
- Future FSMA-based regime (2025-2026) will introduce tiered capital requirements, trading platform rules, lending/staking/stablecoin regimes — structural changes expected
- Safeguarding requirements apply for custody of user assets under current FCA registration + future MiCA-style tiered capital requirements
Key Risks
- Very high FCA rejection rate (~85%) for crypto registration creates significant execution risk — most applicants fail to obtain or maintain registration
- Regulatory regime in transition — current AML-only registration is being replaced by a comprehensive FSMA-based regime (2025-2026), creating uncertainty and potential re-authorization burden
- No services to sanctioned jurisdictions or designated persons globally if UK nexus exists — broad extra-territorial reach of UK sanctions
- FCA enforcement track record includes clashes with major exchanges (e.g., Binance) — fines, suspensions, or permanent closures for unregistered firms
- Travel Rule at GBP 0 threshold means every single withdrawal must carry originator/beneficiary info — significant operational lift for all on-chain transactions
- Unlimited fines and asset seizures for non-compliance with AML/sanctions obligations
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
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).
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.
Custodian wallet providers currently need MLR registration, which imposes AML/CTF duties only and no safeguarding rules; from 25 October 2027 safeguarding qualifying cryptoassets is a regulated activity (RAO art 9N, SI 2026/102) requiring FCA authorisation, the FCA applies CASS 17 to client cryptoassets, and CRYPTOPRU prudential requirements apply (PS26/12, 30 June 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.
Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) – The Money Laundering Regulations 2017 (MLRs):
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.
A "cryptoasset exchange provider" under MLRs 2017 reg 14A is a firm or sole practitioner that by way of business exchanges or arranges the exchange of cryptoassets for money or money for cryptoassets, exchanges one cryptoasset for another, or operates a machine (crypto ATM) that exchanges cryptoassets for money — including where it is the creator or issuer of the cryptoassets involved.
A "custodian wallet provider" under MLRs 2017 reg 14A is a firm or sole practitioner that by way of business provides services to safeguard, or to safeguard and administer, cryptoassets on behalf of its customers, or private cryptographic keys on behalf of its customers in order to hold, store and transfer cryptoassets.
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.
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 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.
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.
Travel Rule adopted — MLRs 2017 Part 7A (regulations 64A–64H, inserted by SI 2022/860 and in force 1 September 2023): the originator's cryptoasset business must send the originator and beneficiary information in regulation 64C(5) with every inter-cryptoasset-business transfer, and where regulation 64C(3) does not apply must add the fuller originator identifiers in regulation 64C(6) for transfers equal to or exceeding £800 in value, a sum substituted with effect from 30 June 2026 by SI 2026/621 regulation 32.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — centralized exchanges may operate in the UK only after obtaining FCA registration (high bar, ~85% rejection rate), complying with full AML/CTF/Travel Rule obligations (GBP 0 threshold), adhering to financial promotions rules, and facing a transitioning regime toward comprehensive FSMA-based authorization by 2025-2026.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?