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FCA Proposes Crypto Financial Crime Guidance on Customer Checks and Analytics

The UK regulator is consulting until Dec. 24 on updated Financial Crime Guide examples for crypto firms, including blockchain analytics, Travel Rule checks and transaction monitoring. The guidance would not create new rules.
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FCA Proposes Crypto Financial Crime Guidance on Customer Checks and Analytics

The Financial Conduct Authority is consulting on updated financial crime guidance for cryptoasset businesses, setting out proposed examples of good and poor practice for customer due diligence, blockchain analytics and transaction monitoring.

The Oct. 23 consultation proposes changes to the regulator’s Financial Crime Guide, covering cryptoassets alongside fraud, sanctions, data security and money laundering. The proposals apply to the FCA’s financial crime supervisory population, including cryptoasset businesses and firms overseen under the Money Laundering Regulations.

The practical focus is on how firms assess customers and transactions, and how they respond when risk changes. The paper notes that a blockchain record can help an investigation, but a record alone does not decide whether a customer explanation is credible or whether a transfer needs further scrutiny.

Analytics must sit inside a working control system

The consultation proposes examples of good and poor practice for enhanced due diligence, onboarding and transaction monitoring. It specifically addresses the use of blockchain analytics and provides further guidance on the Travel Rule, which concerns information accompanying certain transfers.

The paper also reminds firms that governance must evolve as their businesses grow. Its proposed changes include a question about whether policies and staff training distinguish obligations under proceeds-of-crime legislation from those under terrorism legislation.

For an exchange or a provider of custody, the implication is that buying a screening product is only one part of the job. Someone still has to set its thresholds, review alerts and document decisions. A technically accurate warning is of limited use if it sits unreviewed while funds move elsewhere.

That matters for stablecoin transfers as much as for volatile tokens. A stable unit price does not establish the identity of a sender or the origin of funds. Transaction risk and market risk are different questions, and control systems need to reflect that distinction.

Guidance now, a wider regime in 2027

The FCA says the guide contains no rules and imposes no new requirements. It is intended to help firms understand supervisory expectations and assess their own arrangements. The consultation closes on Dec. 24, after which the regulator plans to publish feedback and the final text in a policy statement.

Separately, the FCA’s regime overview says the wider cryptoasset framework is expected to begin on Oct. 25, 2027. Applications for authorization are already open, and the regulator published a package of final rules in June.

The distinction between those stages matters for firms planning investment in compliance. The consultation does not postpone existing anti-money-laundering duties until next year, nor does it bring the whole future regime into force immediately. It fills in proposed guidance firms can use when translating their obligations into day-to-day decisions.

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