Joshua Deeks, AICA.,

FCA Consultation - Application of FCA Handbook for Regulated Cryptoasset Activities The FCA wants to develop a competitive and sustainable cryptoasset sector – one that enables innovation and is underpinned by market integrity and consumer protection. CP25/25 looks at how the existing FCA Handbook rules will apply to future regulated cryptoasset firms. The FCA is consulting on how its existing FCA Handbook rules will apply to firms, including High Level Standards such as the Senior Management Arrangements, Systems and Controls (SYSC) Sourcebook (including governance, Senior Managers and Certification Regime, financial crime and operational resilience), and Business Standards (specifically the Environmental, Social and Governance Sourcebook). The FCA is also seeking views on its approach to the Consumer Duty, Business Standards such as the Conduct of Business Sourcebook, Product Intervention and Product Governance Sourcebook, Redress (Dispute Resolution: Complaints) and application of the Financial Ombudsman Service under the new cryptoasset regime.  Currently, the FCA cryptoasset rules cover financial promotions and preventing financial crime. As part of the FCA's Crypto Roadmap, its regulatory remit will expand to a more comprehensive cryptoassets regime to be set out in HM Treasury’s forthcoming legislation. Under the FCA's proposals, consumers will be better protected from poor operational business practices, helping to build trust in the sector. Firms will need to be operationally resilient and requirements on firms to have systems and controls to fight crime will be strengthened.  Firms and individuals conducting these new regulated activities will need to apply for authorisation before carrying out any of them by way of business in the UK.

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Reflections from the Crypto Frontier Approaching 18 months as a Head of Compliance in the crypto industry, I’ve had time to reflect on what makes this space unlike any other I’ve worked in. Crypto moves fast — by design. Innovation is constant, change is relentless, and the pressure to scale responsibly is real. In this environment, compliance can’t just follow the pace — it has to match it. That means evolving from a reactive mindset to a proactive, embedded presence. It’s about working closely with sales, product, engineering, and legal teams, and leveraging the same innovative energy that fuels the entire ecosystem. Speed doesn’t have to come at the cost of control. When compliance is agile and collaborative, it becomes a true business enabler. Our role isn’t to slow things down — it’s to help the business move fast, with confidence. That means building frameworks that are robust, scalable, and trusted by regulators, partners, and customers alike. In a landscape where the rules are still catching up, our responsibility is clear: lead with integrity, innovate responsibly, and show that compliance and creativity not only coexist — they can thrive together. I’m fortunate to collaborate with exceptional compliance leaders — Andrew Price, Hema Patel and Suraj Upareeswaran — whose expertise, integrity, and drive continue to inspire and elevate the work we do every day. #Compliance #Crypto #Innovation #Leadership #RiskManagement

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🇬🇧 The UK OFSI has published a crypto assets threat assessment packed with tips and best practices for crypto sanctions compliance and I wish I had it back in 2027 ;) Starting by stating the obvious eg 𝐅𝐢𝐧𝐚𝐧𝐜𝐢𝐚𝐥 𝐬𝐚𝐧𝐜𝐭𝐢𝐨𝐧𝐬 𝐫𝐞𝐠𝐮𝐥𝐚𝐭𝐢𝐨𝐧𝐬 𝐝𝐨 𝐧𝐨𝐭 𝐝𝐢𝐟𝐟𝐞𝐫𝐞𝐧𝐭𝐢𝐚𝐭𝐞 𝐛𝐞𝐭𝐰𝐞𝐞𝐧 𝐜𝐫𝐲𝐩𝐭𝐨 𝐚𝐧𝐝 𝐨𝐭𝐡𝐞𝐫 𝐟𝐨𝐫𝐦𝐬 𝐨𝐟 𝐚𝐬𝐬𝐞𝐭𝐬. 📜 The OFSI also shares key findings on compliance with sanctions regulations by UK crypto assets providers highlighting 𝐮𝐧𝐝𝐞𝐫 𝐫𝐞𝐩𝐨𝐫𝐭𝐢𝐧𝐠, 𝐥𝐚𝐜𝐤 𝐨𝐟 𝐜𝐨𝐦𝐩𝐥𝐢𝐚𝐧𝐜𝐞 especially due to confusion regarding indirect exposure, exposure to Guarantex and Iranian crypto firms with suspected links to designate persons (DPs), and the risk of being targeted by DPRK-linked hackers and IT workers. ⭐ I m more interested in 𝐭𝐡𝐞 𝐭𝐢𝐩𝐬: ✔️ Using real time blockchain analytics tools connecting 𝐨𝐧 𝐚𝐧𝐝 𝐨𝐟𝐟 𝐜𝐡𝐚𝐢𝐧 𝐝𝐚𝐭𝐚 ✔️ Complexity of detecting exposure to crypto addresses suspected to be owned or controlled by DPs, but where the crypto addresses are not listed on a sanction list,  ✔️Recommendation to scan 3-5 𝐡𝐨𝐩𝐬 𝐦𝐢𝐧𝐢𝐦𝐮𝐦 𝐢𝐧 𝐭𝐫𝐚𝐧𝐬𝐚𝐜𝐭𝐢𝐨𝐧 𝐡𝐢𝐬𝐭𝐨𝐫𝐲 or until the asset reach an attributed service provider and report any suspicious activity to OFSI, ✔️Screening should is not limited to onboarding. Screening needs to be continuous and dynamic and applies to senders, receivers, counterparties, and intermediaries, especially where routing via decentralized protocols ✔️ When identification of transactions involving DPs after they occurred (i.e. in cases where the addresses are attributed at a later point, or where historical breaches are discovered after the acquisition of clustering blockchain analytics tools) reporting is mandatory ✔️ 𝐂𝐫𝐲𝐩𝐭𝐨𝐚𝐬𝐬𝐞𝐭 𝐟𝐢𝐫𝐦𝐬 𝐜𝐚𝐧𝐧𝐨𝐭 𝐫𝐞𝐣𝐞𝐜𝐭 𝐢𝐧𝐜𝐨𝐦𝐢𝐧𝐠 𝐭𝐫𝐚𝐧𝐬𝐚𝐜𝐭𝐢𝐨𝐧𝐬. When incoming assets are linked to suspected sanctions evasion activities, firms should restrict users from accessing an account and transferring those assets ✔️ Map and understand exposure to sanctioned jurisdictions and high-risk services. Firms must actively map their asset flows, and identify direct exposure to sanctioned entities or services, indirect exposure via chain hops, liquidity providers, or protocols with material ties to sanctioned jurisdictions, use of anonymizing technologies ✔️Establish Clear Escalation and Reporting Mechanisms ✔️𝐃𝐨𝐜𝐮𝐦𝐞𝐧𝐭𝐚𝐭𝐢𝐨𝐧 𝐚𝐧𝐝 𝐚𝐮𝐝𝐢𝐭𝐚𝐛𝐢𝐥𝐢𝐭𝐲 to demonstrate why forms did or did not flag a transaction, how their controls function and are updated, that they took reasonable steps to mitigate risk, even where full visibility is limited ✔️List of redflags and case studies ✔️ Information required when filling in a SAR 🥷 This is only the tip of the iceberg, 𝐝𝐞𝐭𝐞𝐜𝐭𝐢𝐧𝐠 𝐭𝐫𝐚𝐝𝐞 𝐬𝐚𝐧𝐜𝐭𝐢𝐨𝐧𝐬 𝐞𝐯𝐚𝐬𝐢𝐨𝐧 𝐢𝐬 𝐚 𝐦𝐮𝐜𝐡 𝐦𝐨𝐫𝐞 𝐜𝐨𝐦𝐩𝐥𝐞𝐱 𝐛𝐞𝐚𝐬𝐭 Vince Turcotte ;) Solidus Labs #cryptocompliance #sanctions

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ISO 20022 Migration: What’s Next After November 2025? By November 2025, the coexistence of legacy formats and ISO 20022 for cross-border payments will formally end—but the migration journey is far from over. A phased transition has now been outlined for the rest of the financial messaging ecosystem. Here’s what financial institutions need to know: 🔹 Structured Data First Structured or hybrid postal addresses will be mandatory starting 2026. Free-text address fields will no longer be accepted in payment messages. This is a crucial step toward improving data quality and downstream automation. 🔹 Legacy MT Instructions Retired Popular message types for customer and institutional payments will be decommissioned. ISO 20022 equivalents are now the default for all new payment flows, with interim conversion services subject to additional scrutiny and cost. 🔹 Exception & Investigation Flows Are Changing Manual message chains for investigating payments are being replaced by ISO-native case messages and digital case handling frameworks. By 2027, legacy formats for E&I and payment cancellations will be retired. 🔹 Reporting & Statements Going ISO Account statements and balance messages will move to the ISO 20022 standard by 2028. Institutions must be ready to receive and reconcile camt-based messages by 2027 to avoid disruptions. 🔹 Other Domains to Follow Initiation messages, direct debits, and cheque flows are now on a staged path to ISO 20022, with cutover dates ranging from 2026 to 2028. At Nth Exception, we’re already helping FIs make the shift to ISO 20022-native operations. Full Details https://lnkd.in/gKwEHBAP Knowledge Centre #iso20022 #payments #swift

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