A structured checklist for crypto-asset businesses covering token accounting, HMRC reporting, AML controls and financial disclosures under MiCA and the UK regime.
1. Accounting & Financial Reporting
- Accounting policy for crypto assets documented and board-approved Cost model or fair value election made; policy consistent with IFRS or FRS 102 as applicable.
- Crypto asset register maintained Each asset listed with acquisition date, cost, and current fair value; updated at each reporting date.
- Impairment testing policy in place Trigger events defined and review frequency set; impairment losses recognised promptly.
- Disposal accounting: gain / loss calculated consistently FIFO or identified cost basis applied consistently; method documented and approved by auditor.
- Token issuance accounting treatment confirmed Treatment as liability, equity, or revenue documented and board-approved before any issuance.
- Staking and DeFi income: recognition policy confirmed Revenue recognition timing and measurement basis documented and consistently applied.
- Intercompany crypto transfers: arm’s length pricing policy in place Transfer pricing methodology documented for all intra-group token movements.
2. HMRC Tax Compliance
- Corporation tax position reviewed Crypto disposals correctly treated as chargeable gains; pooling rules applied as appropriate.
- Mining / staking income: trading income treatment Assessed at commercial scale; income reported correctly on corporate tax return.
- Employment-related securities: employee token grants reviewed Income tax and NI implications assessed; reportable events identified and reported to HMRC.
- VAT treatment confirmed Crypto exchange and token issuance activities assessed; exempt, outside scope, or taxable position documented.
- Transfer pricing documentation in place Master and local file prepared for material cross-border intra-group transactions.
- HMRC notification obligations addressed Any s.8 notices or crypto information requests responded to within required timeframe.
3. AML & Financial Crime Controls
- FCA crypto asset registration status confirmed Business registered or within the transitional exemption; no unregistered activities being conducted.
- Risk assessment completed Inherent risks from anonymity, DeFi interactions, and cross-chain transactions documented and rated.
- Customer due diligence: source of funds / wealth checks Enhanced checks triggered for high-value crypto transactions; documentation retained.
- Transaction monitoring: on-chain analytics tool deployed Tool such as Chainalysis or Elliptic in place; alert thresholds reviewed and calibrated.
- Sanctions screening: wallet address screening active Screening covers OFAC, HMT, and EU consolidated lists; frequency and coverage confirmed.
- SAR reporting: designated MLRO in place All internal reports reviewed by MLRO within agreed timeframe; external SARs filed where required.
4. MiCA & UK Regulatory Compliance
- MiCA applicability assessed Analysis complete for whether the business issues or provides services in the EU relating to ARTs or EMTs.
- White paper obligations: compliant white paper published Required where issuing tokens under MiCA; disclosure content reviewed by legal counsel.
- UK FCA authorisation / registration status confirmed All in-scope activities covered by registration or authorisation; no regulatory gaps identified.
- Travel Rule compliance in place VASP-to-VASP information transfer process operational for transfers above the threshold amount.
- Regulatory change log maintained Tracker covers FCA Policy Statements and MiCA technical standards; assigned owner updates monthly.
5. Investor & Audit Disclosure
- Crypto asset disclosures in annual accounts IFRS or FRS 102 compliant notes drafted; accounting policies, fair values, and risk disclosures included.
- Auditor briefed on crypto asset holdings and transaction volumes Audit approach agreed; access to on-chain data and valuation sources confirmed.
- Investor reporting: crypto treasury position disclosed Monthly update includes current holdings, fair value, and any material movements during the period.
- Board-approved treasury policy for crypto holdings Exposure limits, liquidation triggers, and custodian arrangements documented and signed off.
