Services About Legal & Compliance Advisory Desk Partners Toolkit
Theme
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Service 01 · FCA · MiCA · UK & EU

Authorisation
& Licensing.

End-to-end support through the FCA and MiCA CASP authorisation process, from initial perimeter analysis and regulatory business plan drafting through to application submission and ongoing regulatory dialogue. Every application is built from scratch to the FCA's assessment criteria, not adapted from a template.

Request Introduction → Free Readiness Toolkit
What We Deliver

The specific outputs
of each engagement.

01
Perimeter Analysis & Strategy

Before any application work begins, we map your business model against the regulatory perimeter, confirming which activities are regulated, which permission set applies, and what the optimal application strategy is for your timeline and structure.

  • Regulated activity identification and mapping
  • Permission set design, precise scope, no over-application
  • Jurisdiction selection for MiCA (NCA processing timelines)
  • Third-country regime assessment for non-UK/EU entities
  • Pre-application FCA engagement strategy (Innovation Pathways)
02
Regulatory Business Plan

The single most common cause of FCA application rejection is a regulatory business plan that does not meet the FCA's assessment criteria. We write the RBP from scratch, structured to what the FCA actually looks for, governance, financial projections, risk framework, compliance obligations map, Consumer Duty evidence.

  • 3-year financial projections with stress & wind-down scenarios
  • Governance structure and board composition narrative
  • Regulatory obligations map, sourcebook by sourcebook
  • Consumer Duty implementation plan with evidenced outcomes
  • Risk appetite statement and risk framework overview
03
SMCR Mapping

All FCA-authorised firms require designated Senior Managers. We identify the applicable SMF functions, prepare Form A applications for each proposed holder, and draft granular Statements of Responsibilities, the FCA returns generic SoRs as insufficient.

  • SMF function identification and holder assessment
  • Form A preparation for each SMF holder
  • Granular Statements of Responsibilities (not generic)
  • Responsibilities Map (enhanced scope firms)
  • Fitness and propriety documentation support
04
Policies & Procedures Suite

A complete regulatory policy suite built for the specific permission set, not a generic library. Covers the compliance monitoring programme, complaints handling, conflicts, operational resilience, outsourcing, and financial crime, each written against the applicable FCA sourcebook.

  • Compliance monitoring programme (annual plan)
  • Complaints handling, DISP-compliant timeframes
  • Conflicts of interest policy (SYSC / MiFID II)
  • Operational resilience, important business services
  • Outsourcing and third-party register
05
MiCA White Paper & CASP Application

For MiCA CASP applications, we advise on white paper structure against the mandatory Article 5/19/51 content requirements, review the liability provisions and right of withdrawal, and prepare the organisational and prudential documentation required by the NCA.

  • White paper review, MiCA mandatory content (ESMA RTS)
  • Liability & right of withdrawal provisions (Art. 14)
  • Prudential requirements, own funds minimum assessment
  • Management body suitability documentation (Art. 68)
  • Custody safeguarding arrangements (Art. 70)
06
Wind-Down Planning

The FCA requires every authorised firm to demonstrate orderly wind-down capability, and for digital asset businesses, this is operationally complex. We design the wind-down plan, model the minimum capital requirement, and map the mechanism for returning client cryptoassets.

  • Wind-down trigger events and escalation authority
  • Minimum capital requirement for orderly wind-down
  • Client asset return mechanism, on-chain and fiat
  • Regulatory notification obligations and timeline
  • Wind-down scenario modelling in financial projections
Regulatory Basis

The frameworks
we work within.

FSMA 2000 · Part 4A
FCA Cryptoasset Authorisation Gateway
The Part 4A FSMA gateway for cryptoasset businesses opens September 2026. Requires specific permission set, regulatory business plan, and SMCR compliance. Replaces the MLR 2017 temporary registration regime.
MLRs 2017 (as amended)
Cryptoasset Business Registration
Current registration regime for UK cryptoasset businesses. Compliance does not satisfy Part 4A requirements, firms must re-apply under the new gateway.
FCA PS22/9
Consumer Duty
Applies to all FCA-authorised firms serving retail customers. Must be evidenced in the application, not a statement of intent. Four outcome areas: products, price and value, understanding, support.
MiCA, Regulation 2023/1114
Markets in Crypto-Assets Regulation
EU CASP authorisation regime. In force from December 2024. Covers 10 crypto-asset service types. Jurisdiction selection, NCA timelines, and white paper requirements are central to strategy.
SYSC · SMCR · SUP
FCA Sourcebook Requirements
Systems and controls, Senior Managers regime, and supervision requirements. Every regulatory business plan must map obligations against the applicable sourcebook modules.
FCA PS21/3
Operational Resilience
Requires identification of important business services, impact tolerances, and tested wind-down capability. Applies to all FCA-authorised firms.
How We Work

The engagement
model.

01
Perimeter Review

We assess your business model, activities, and proposed structure against the regulatory perimeter. Output: written perimeter analysis and recommended permission set.

02
Governance & Structure

We map your governance structure, identify SMF holders, and design the board and management framework required to support the application.

03
Application Build

We draft the regulatory business plan, SMCR documents, policy suite, and financial model. Each document is built specifically for your firm, not from a template library.

04
Submission & Dialogue

We manage the submission and all FCA or NCA correspondence, including responses to information requests, requisitions, and gateway meetings.

Start the Preparation
The Part 4A gateway opens
September 2026. Preparation starts now.
Request Introduction → Read our FCA Authorisation Guide