How to use this checklist: Work through each section before submitting your FCA crypto asset business registration application. Each item reflects a documented common failure point from FCA rejection decisions. Incomplete governance evidence and AML policy gaps are the two most frequent reasons for refusal — these sections deserve the most preparation time.
1. Business Model & Scope
- Regulated crypto activity definedWhich FCA crypto activities apply to the business model — confirmed and documented with reference to the relevant MLR 2017 definitions.
- Customer segments documentedRetail, professional, and institutional customer types identified — each with a distinct risk profile and differentiated treatment in the application.
- Product and services descriptionAll crypto asset activities clearly described — no ambiguity about what the firm does and does not do within the scope of registration.
- Geographic scopeJurisdictions served documented; any EU nexus assessed for MiCA compliance requirements and noted in the application.
- Business plan signed off by boardBoard-approved business plan covering strategy, three-year financial projections, and the firm's overall risk approach.
2. Governance & Fit and Proper
- Ultimate beneficial owners (UBOs) identifiedAll persons with more than 10% ownership or control documented — full legal names, nationality, and ownership percentages confirmed.
- Fit and proper assessments completed for all principalsCriminal record checks and financial history reviews conducted for every principal — results documented and retained.
- CVs prepared for all principals and senior managementDetailed CVs evidencing crypto and finance experience for each individual named in the application.
- Board composition documentedNon-executives identified where required by FCA expectations; composition rationale documented.
- Governance frameworkBoard meeting cadence, risk committee structure, and compliance reporting lines all documented and operational.
- Group structure chartAll entities in the group shown with ownership percentages — chart accurate as of application date and signed off by a director.
3. AML/CTF Framework
- AML policy and procedures drafted and board-approvedComprehensive policy covering all FCA requirements — board approval minuted and dated before application submission.
- Risk assessment completedBusiness-wide ML/TF risk assessment documented — covers customer, product, geographic, and channel risk factors.
- Customer due diligence proceduresStandard, enhanced, and simplified CDD procedures each documented with specific triggers, steps, and evidence requirements.
- Suspicious activity reporting (SAR) procedureMLRO designated; internal SAR reporting process documented from staff detection through to NCA submission where required.
- Transaction monitoringSystem identified and tested — detection rules, thresholds, and alert escalation process all documented.
- Sanctions screeningOFAC, HMT, and EU list screening tool confirmed and live — process tested and results documented.
- Staff trainingAML training programme in place; records showing all relevant staff have completed training before go-live.
4. Financial Resources
- Opening balance sheet showing adequate financial resourcesBalance sheet demonstrating sufficient capital to operate — reviewed against FCA adequacy expectations for the activity type.
- Bank account in the name of the UK entityAccount held in the UK entity's name (not a group entity) — confirmed open and operational before submission.
- Three-year financial projections demonstrating sustainabilityProjections show a credible path to sustainability — assumptions documented and consistent with the business plan.
- Source of funds for capitalisationShareholder loans, equity injections, or other funding sources clearly documented with supporting evidence.
5. Application Mechanics
- FCA Connect accessAccount created on FCA Connect; full application form reviewed in its entirety before beginning to populate it.
- Registration feeCorrect fee amount identified based on risk category — payment method confirmed and funds available.
- Supporting document packIndexed list of all attachments prepared — each document mapped to the specific question it addresses in the application form.
- Legal reviewApplication reviewed in full by crypto-specialist regulatory legal counsel before submission.
