Compliance
UK FCA Regulatory licenses
Securing authorisation from the Financial Conduct Authority (FCA) is one of the most complex and scrutinised regulatory processes in global financial services. It is not a form-filling exercise. It is a forensic assessment of governance, capital, systems, controls, people, and culture. We specialise in guiding firms through FCA authorisation and regulatory change with precision, credibility, and regulatory realism.
WHAT WE DO
We provide end-to-end support across the full FCA licensing lifecycle, including:
– Electronic Money Institutions (EMI / AEMI)
– Payment Institutions (API / SPI)
– Cryptoasset firms (UK MLR registration and post-registration governance uplift)
– Regulatory permissions variations, restructures, and remediation
– Pre-application feasibility and refusal recovery
Our approach is designed for firms that want to get authorised properly the first time—and for those that need to recover from a failed or fragile application.
– Electronic Money Institutions (EMI / AEMI)
– Payment Institutions (API / SPI)
– Cryptoasset firms (UK MLR registration and post-registration governance uplift)
– Regulatory permissions variations, restructures, and remediation
– Pre-application feasibility and refusal recovery
Our approach is designed for firms that want to get authorised properly the first time—and for those that need to recover from a failed or fragile application.
OUR REGULATORY APPROACH
The FCA assesses firms on substance, not aspiration. We therefore focus on:
– Governance that works: Board composition, independence, SMF accountability, decision-making frameworks
– Regulatory capital and safeguarding realism; not theoretical spreadsheets
– Operational resilience: systems, controls, outsourcing, and third-party risk
– Clear regulatory perimeter articulation: what you do, what you don’t do, and why
– Credible compliance ownership: not box-ticking or outsourced accountability
Every document we produce is FCA-ready, tailored to your business model, and aligned to the FCA Handbook, EBA Guidelines, and current supervisory expectations.
– Governance that works: Board composition, independence, SMF accountability, decision-making frameworks
– Regulatory capital and safeguarding realism; not theoretical spreadsheets
– Operational resilience: systems, controls, outsourcing, and third-party risk
– Clear regulatory perimeter articulation: what you do, what you don’t do, and why
– Credible compliance ownership: not box-ticking or outsourced accountability
Every document we produce is FCA-ready, tailored to your business model, and aligned to the FCA Handbook, EBA Guidelines, and current supervisory expectations.
01.
OUR SERVICES INCLUDE
– Full FCA authorisation project management
– Drafting and ownership of the Regulatory Business Plan (RBP)
– SMF16 / SMF17 / SMF compliance structuring and role mapping
– Bespoke policy and framework development (SYSC, PRIN, Consumer Duty, AML/CTF, Safeguarding)
– FCA application forms, regulatory narratives, and supervisory correspondence
– Pre-submission challenge and regulator-style gap analysis
– Post-authorisation governance uplift and ongoing compliance advisory
02.
Why Clients Choose Us
– We work as regulators expect firms to operate, not how consultants wish they did
– We have deep experience with cross-border groups, complex ownership structures, and fintech business models
– We understand where applications fail and how to prevent it
– We engage directly with Boards, founders, and senior management, not just project teams.
Most importantly, we do not dilute accountability. Regulatory ownership remains with you, but you are supported by senior specialists who have done this before.
03.
WHO WE WORK WITH
– Fintech founders preparing for first-time authorisation
– Established groups entering the UK market
– Firms recovering from FCA refusals or withdrawals
– Boards requiring independent regulatory challenge and credibility
Virtual assets services
Virtual asset businesses operating at scale face a regulatory environment that is fragmented, fast-moving, and increasingly unforgiving. Across jurisdictions, regulators are converging on a single expectation: substance over structure, governance overgrowth, and accountability over innovation. We advise virtual asset and crypto businesses globally, helping them establish credible, regulator-defensible frameworks that withstand scrutiny across borders, not just at the point of authorisation, but throughout their operating life. Our work sits at the intersection of regulation, governance, and financial crime risk, supporting firms that require clarity, confidence, and discretion.
OUR GLOBAL PERSPECTIVE
We support clients navigating regulatory regimes influenced by:
– The Financial Conduct Authority and UK financial crime supervision.
– EU and EEA AML frameworks and supervisory expectations.
– Middle East virtual asset regimes (including licensing, governance, and operational readiness).
– International standards set by the Financial Action Task Force (FATF).
– Cross-border group structures with multiple regulators and enforcement risk.
We do not treat jurisdictions in isolation. We design frameworks that scale internationally while remaining locally defensible.
– The Financial Conduct Authority and UK financial crime supervision.
– EU and EEA AML frameworks and supervisory expectations.
– Middle East virtual asset regimes (including licensing, governance, and operational readiness).
– International standards set by the Financial Action Task Force (FATF).
– Cross-border group structures with multiple regulators and enforcement risk.
We do not treat jurisdictions in isolation. We design frameworks that scale internationally while remaining locally defensible.
WHAT WE ADVISE ON
We work with firms across the virtual asset ecosystem, including:
– Crypto exchanges and trading platforms.
– Custody, wallet, and asset servicing providers.
– On- and off-ramp payment models.
– Token issuers and structured crypto products.
– Web3 and DeFi-adjacent businesses (where regulatory perimeter applies).
Our clients range from early-stage entrants to established global groups requiring regulatory consolidation, remediation, or expansion support.
– Crypto exchanges and trading platforms.
– Custody, wallet, and asset servicing providers.
– On- and off-ramp payment models.
– Token issuers and structured crypto products.
– Web3 and DeFi-adjacent businesses (where regulatory perimeter applies).
Our clients range from early-stage entrants to established global groups requiring regulatory consolidation, remediation, or expansion support.
REGULATORY & GOVERNANCE SERVICES
Our advisory services include:
– Global crypto / VASP regulatory strategy and jurisdictional mapping.
– Licensing and registration support across multiple regimes.
– Regulatory perimeter analysis and activity classification.
– AML / CTF frameworks aligned to crypto-specific risks.
– FATF Travel Rule readiness and implementation.
– Board-level governance, accountability, and senior management structuring.
– Remediation of refused, withdrawn, or stalled applications.
– Ongoing supervisory readiness and regulatory engagement support.
Every engagement is tailored. We do not sell templates, shortcuts, or “crypto-friendly” narratives.
– Global crypto / VASP regulatory strategy and jurisdictional mapping.
– Licensing and registration support across multiple regimes.
– Regulatory perimeter analysis and activity classification.
– AML / CTF frameworks aligned to crypto-specific risks.
– FATF Travel Rule readiness and implementation.
– Board-level governance, accountability, and senior management structuring.
– Remediation of refused, withdrawn, or stalled applications.
– Ongoing supervisory readiness and regulatory engagement support.
Every engagement is tailored. We do not sell templates, shortcuts, or “crypto-friendly” narratives.
01.
OUR PHILOSOPHY
We believe credibility is the ultimate regulatory asset.
That means:
– Clear ownership of financial crime risk.
– Governance structures that function under pressure.
– Controls that are auditable, explainable, and proportionate.
– Regulatory narratives that withstand challenge.
We work as regulators expect firms to operate; calmly, coherently, and with discipline.
That means:
– Clear ownership of financial crime risk.
– Governance structures that function under pressure.
– Controls that are auditable, explainable, and proportionate.
– Regulatory narratives that withstand challenge.
We work as regulators expect firms to operate; calmly, coherently, and with discipline.
02.
A DISCREET, SENIOR-LED APPROACH
Our clients value:
– Direct access to senior regulatory specialists.
– Independence from product, technology, or exchange incentives.
– Discretion when navigating sensitive regulatory or supervisory matters.
– Advice that balances commercial reality with regulatory integrity.
We act as a trusted advisor to Boards, founders, and senior leadership—particularly where regulatory decisions carry existential or reputational risk.
– Direct access to senior regulatory specialists.
– Independence from product, technology, or exchange incentives.
– Discretion when navigating sensitive regulatory or supervisory matters.
– Advice that balances commercial reality with regulatory integrity.
We act as a trusted advisor to Boards, founders, and senior leadership—particularly where regulatory decisions carry existential or reputational risk.
03.
WHO WE WORK WITH
– Global virtual asset firms expanding into new jurisdictions.
– Groups rationalising or remediating complex regulatory footprints.
– Firms facing heightened supervisory scrutiny or enforcement risk.
– Boards seeking independent regulatory challenge and credibility.
– Founders who understand that regulation is a strategic function, not an afterthought.
Money service business (MSB)
Licensing, Regulatory & Governance Advisory
Money Services Businesses operate at one of the most heavily scrutinised points in the global financial system. Payments, foreign exchange, remittance, and money transmission models attract intense regulatory oversight, heightened financial crime expectations, and sustained pressure from correspondent banks, often across multiple jurisdictions at once. We advise MSBs globally, supporting firms through licensing, registration, and long-term regulatory sustainability, with a focus on credibility, governance, and control ownership. Our work is designed not only to secure regulatory approval, but to ensure firms can operate, scale, and retain banking access once authorised.
A GLOBAL, REGULATOR-LED PERSPECTIVE
We support MSBs operating under, or influenced by, supervisory regimes including:
– The Financial Conduct Authority and UK payments / AML supervision.
– EU and EEA payment services and AML frameworks.
– North American MSB and money transmission regimes.
– Middle East and offshore financial centre supervision.
– International standards set by the Financial Action Task Force (FATF).
Our approach recognises that MSBs are assessed not only by regulators, but by banks, clearing institutions, payment partners, and auditors, each applying their own risk tolerance and expectations.
– The Financial Conduct Authority and UK payments / AML supervision.
– EU and EEA payment services and AML frameworks.
– North American MSB and money transmission regimes.
– Middle East and offshore financial centre supervision.
– International standards set by the Financial Action Task Force (FATF).
Our approach recognises that MSBs are assessed not only by regulators, but by banks, clearing institutions, payment partners, and auditors, each applying their own risk tolerance and expectations.
MSB LICENSING & REGISTRATION SERVICES
We provide end-to-end support for MSB licence and registration applications globally, including:
– Pre-application feasibility and jurisdictional suitability assessments.
– Regulatory perimeter and activity classification.
– Licensing and registration strategy across multiple jurisdictions.
– Drafting and ownership of regulatory applications and narratives.
– Business plans, financial crime risk assessments, and governance frameworks.
– Senior management, Board, and compliance role structuring.
– Regulator engagement, queries, and supervisory correspondence.
– Recovery and remediation of refused, withdrawn, or stalled applications.
Our licensing work is regulator-facing, detailed, and defensible, built to withstand challenge, not simply pass an initial review.
– Pre-application feasibility and jurisdictional suitability assessments.
– Regulatory perimeter and activity classification.
– Licensing and registration strategy across multiple jurisdictions.
– Drafting and ownership of regulatory applications and narratives.
– Business plans, financial crime risk assessments, and governance frameworks.
– Senior management, Board, and compliance role structuring.
– Regulator engagement, queries, and supervisory correspondence.
– Recovery and remediation of refused, withdrawn, or stalled applications.
Our licensing work is regulator-facing, detailed, and defensible, built to withstand challenge, not simply pass an initial review.
01.
WHO WE SUPPORT
We advise a broad range of MSB models, including:
– Money transmitters and remittance providers.
– Foreign exchange and cross-border payments businesses.
– B2B and corporate-focused MSBs.
– Payment intermediaries and settlement agents.
– Multi-jurisdictional groups with complex flows and correspondent dependencies.
We are particularly experienced in supporting firms that must demonstrate enhanced credibility to secure or maintain banking relationships alongside regulatory approval.
– Money transmitters and remittance providers.
– Foreign exchange and cross-border payments businesses.
– B2B and corporate-focused MSBs.
– Payment intermediaries and settlement agents.
– Multi-jurisdictional groups with complex flows and correspondent dependencies.
We are particularly experienced in supporting firms that must demonstrate enhanced credibility to secure or maintain banking relationships alongside regulatory approval.
02.
ONGOING REGULATORY & GOVERNANCE ADVISORY
Beyond licensing, we support MSBs with:
– AML / CTF frameworks proportionate to MSB risk profiles
– Sanctions screening and transaction monitoring governance
– Agent, distributor, and third-party oversight
– Safeguarding, segregation, and client money governance (where applicable)
– Board and senior management accountability structures
– Regulatory remediation and supervisory readiness
– Banking and correspondent due diligence preparation
Our work is tailored, senior-led, and designed to satisfy both regulators and counterparties.
– AML / CTF frameworks proportionate to MSB risk profiles
– Sanctions screening and transaction monitoring governance
– Agent, distributor, and third-party oversight
– Safeguarding, segregation, and client money governance (where applicable)
– Board and senior management accountability structures
– Regulatory remediation and supervisory readiness
– Banking and correspondent due diligence preparation
Our work is tailored, senior-led, and designed to satisfy both regulators and counterparties.
03.
OUR PHILOSOPHY
For MSBs, regulation is not a technical hurdle, it is a strategic dependency.
We focus on:
– Clear ownership of financial crime and operational risk.
– Governance that functions under scrutiny and stress.
– Controls that are explainable, auditable, and proportionate.
– Regulatory narratives that align with how the business truly operates.
We do not offer shortcuts, generic templates, or cosmetic compliance.
– Clear ownership of financial crime and operational risk.
– Governance that functions under scrutiny and stress.
– Controls that are explainable, auditable, and proportionate.
– Regulatory narratives that align with how the business truly operates.
We do not offer shortcuts, generic templates, or cosmetic compliance.
Platform Overview
Who This Is For
– MSBs seeking first-time licensing or registration.
– Firms expanding into new jurisdictions.
– Groups remediating complex or fragile regulatory footprints.
– Businesses facing heightened regulatory or banking scrutiny.
– Boards seeking independent regulatory challenge and credibility.
We Think Like Regulators.
We Do Not Use Templates.
Senior-Led, Always.
Independent by Design.
Built for Scrutiny.
A Discreet, Senior Advisory Model
Our clients value:
– Direct access to senior regulatory specialists.
– Independence from banks, PSPs, and payment platforms.
– Discretion when navigating supervisory or correspondent challenges.
– Advice that balances commercial reality with regulatory integrity.
We act as a trusted advisor to Boards, founders, and senior executives where regulatory approval, banking access, and reputation intersect.
– Direct access to senior regulatory specialists.
– Independence from banks, PSPs, and payment platforms.
– Discretion when navigating supervisory or correspondent challenges.
– Advice that balances commercial reality with regulatory integrity.
We act as a trusted advisor to Boards, founders, and senior executives where regulatory approval, banking access, and reputation intersect.
Our Philosophy
Calm.
Precise.
Defensible.
We build compliance frameworks that regulators respect, counterparties trust, and Boards can stand behind.
Precise.
Defensible.
We build compliance frameworks that regulators respect, counterparties trust, and Boards can stand behind.