🇬🇧 United Kingdom vs 🇺🇸 United States: crypto licensing compared
Decision context and regulator route
United Kingdom's public Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration. and United States's public No single federal crypto licence. Fragmented dual-layer regime: (a) State-level Money Transmitter Licence (MTL), required in 49 states (all except Montana) plus DC, applied for via NMLS (Nationwide Multistate Licensing System) under each state's money transmission statute (31 states have adopted the Money Transmission Modernization Act, MTMA, in full or part as of Feb 2026); (b) Federal FinCEN Money Services Business (MSB) registration under the Bank Secrecy Act, via FinCEN Form 107, required for any business acting as a money transmitter/administrator/exchanger of convertible virtual currency. Some states have specific regimes (e.g., NY BitLicense from NYDFS, 23 NYCRR Part 200) as an alternative/superseding requirement. are set out side by side. Licence type, regulator and public recent-change notes are open; the full dated and sourced comparison is included with access.
United Kingdom: verified 2026-09-01 · United States: verified 2026-08-15
| Dimension |
🇬🇧 United Kingdom
Free in full
Verified 2026-09-01
|
🇺🇸 United States
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration. | No single federal crypto licence. Fragmented dual-layer regime: (a) State-level Money Transmitter Licence (MTL), required in 49 states (all except Montana) plus DC, applied for via NMLS (Nationwide Multistate Licensing System) under each state's money transmission statute (31 states have adopted the Money Transmission Modernization Act, MTMA, in full or part as of Feb 2026); (b) Federal FinCEN Money Services Business (MSB) registration under the Bank Secrecy Act, via FinCEN Form 107, required for any business acting as a money transmitter/administrator/exchanger of convertible virtual currency. Some states have specific regimes (e.g., NY BitLicense from NYDFS, 23 NYCRR Part 200) as an alternative/superseding requirement. |
| Regulator | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. | No single federal crypto regulator. Federally, FinCEN (US Treasury) handles MSB registration and BSA/AML oversight. At the state level, each state's banking/financial-services department (e.g., NYDFS in New York, DFPI in California) issues and supervises money transmitter licences via NMLS. The SEC and CFTC separately assert jurisdiction over certain crypto activities (securities/commodities), the allocation of that jurisdiction is the subject of the pending CLARITY Act. |
| Capital requirement | No minimum initial capital under the current MLR registration. The incoming FSMA regime's final prudential rules (PS26/12, 30 Jun 2026) set Permanent Minimum Requirements by activity: GBP 75,000 (arranging/dealing as agent), 150,000 (custody, trading platform, staking), 350,000 (stablecoin issuance), 750,000 (dealing as principal). | United States capital requirement is included in the £349 pass. |
| Timeline to authorisation | MLR registration: 3-month statutory clock from a COMPLETE application, but realistically ~9-12 months including pre-application; historically low approval rate. | United States timeline to authorisation is included in the £349 pass. |
| Local substance | Business must be carried on in the UK (UK entity in practice); an MLRO / nominated officer (Reg 21(3)) who is UK-based, genuinely competent, independent and closely involved. | United States local substance is included in the £349 pass. |
| Application cost | FCA application fee GBP 11,260 (Category 6, fee-block G23, non-refundable) plus typically GBP 50k-150k in professional fees; ~GBP 90k all-in representative (~EUR 105k at 1.16). | United States application cost is included in the £349 pass. |
| Ongoing cost | Annual FCA periodic fee under fee-block G.30 for 2026/27: minimum GBP 2,251 plus GBP 6.01 per GBP 1,000 of cryptoasset income above GBP 100,000. Plus AML operations, annual audit and compliance headcount; costs rise materially under the incoming FSMA regime. | United States ongoing cost is included in the £349 pass. |
| Passporting | No - post-Brexit the UK regime is standalone; no EU/EEA passport and no MiCA equivalence in either direction. | United States passporting is included in the £349 pass. |
| MiCA CASPs approved | Not applicable: non-MiCA jurisdiction, no CASP regime. See this jurisdiction's own licence route. | United States mica casps approved is included in the £349 pass. |
| Key restrictions | Cryptoasset financial promotions regime (since 8 Oct 2023): mandatory risk warnings, 24-hour cooling-off for first-timers, ban on incentives; plus significant bank de-risking / de-banking of crypto firms. | United States key restrictions is included in the £349 pass. |
| Recent changes | SI 2026/102 made 4 Feb 2026 (laid 5 Feb); FCA final rules published 30 Jun 2026 (PS26/10 stablecoins, PS26/11 regulated activities, PS26/12 prudential); authorisation gateway 30 Sep 2026 to 28 Feb 2027; mandatory FSMA regime from 25 Oct 2027. Current MLR-registered cryptoasset businesses remain in fee-block G.30, whose 2026/27 rates have applied since 2 Jul 2026. CP26/17 separately proposes the annual fee data basis for incoming FSMA-authorised cryptoasset firms; the FCA says it will not charge those annual fees until 2028/29. On 8 July 2026 the FCA published detailed information about the authorisation application form for cryptoasset firms, a full walkthrough of every question the online form will ask; the FCA notes the form's wording may still be refined but its structure is not expected to change, and the online system itself opens for firms to start applications on 30 September 2026 when the gateway opens. Firms have also been able to request a pre-application meeting with the FCA through its PASS service since 11 May 2026, with meetings running from July 2026. | The GENIUS Act's 18 July 2026 deadline for federal implementing rules passed with no agency having finalised a rule: the OCC, FDIC, NCUA and Treasury (with FinCEN and OFAC) have issued proposed rules since December 2025, the Federal Reserve joined a five-agency customer identification proposal on 18 June 2026, and on 27 July 2026 the OCC sought approval for stablecoin issuer application forms (comments due 25 September 2026). The Act sets no penalty for the missed deadline; it takes effect on the earlier of 18 January 2027 or 120 days after final rules. The CLARITY Act remains stalled in the Senate: reported by the Banking Committee on 1 June 2026 with a substitute amendment, no cloture motion filed and no floor vote expected before the August recess; Senate Republicans circulated revised negotiating text on 22 July 2026. The SEC's three planned crypto rulemakings (token issuance safe harbour, broker-dealer capital and custody amendments, market structure) remained unpublished as of late July 2026. |
| Difficulty rating | 4 - rigorous AML bar, historically low approval rate and severe bank-access friction; the incoming FSMA prudential/conduct regime raises the bar further. | United States difficulty rating is included in the £349 pass. |
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What changed recently
🇬🇧 United Kingdom (verified 2026-09-01): SI 2026/102 made 4 Feb 2026 (laid 5 Feb); FCA final rules published 30 Jun 2026 (PS26/10 stablecoins, PS26/11 regulated activities, PS26/12 prudential); authorisation gateway 30 Sep 2026 to 28 Feb 2027; mandatory FSMA regime from 25 Oct 2027. Current MLR-registered cryptoasset businesses remain in fee-block G.30, whose 2026/27 rates have applied since 2 Jul 2026. CP26/17 separately proposes the annual fee data basis for incoming FSMA-authorised cryptoasset firms; the FCA says it will not charge those annual fees until 2028/29. On 8 July 2026 the FCA published detailed information about the authorisation application form for cryptoasset firms, a full walkthrough of every question the online form will ask; the FCA notes the form's wording may still be refined but its structure is not expected to change, and the online system itself opens for firms to start applications on 30 September 2026 when the gateway opens. Firms have also been able to request a pre-application meeting with the FCA through its PASS service since 11 May 2026, with meetings running from July 2026.
🇺🇸 United States (verified 2026-08-01): The GENIUS Act's 18 July 2026 deadline for federal implementing rules passed with no agency having finalised a rule: the OCC, FDIC, NCUA and Treasury (with FinCEN and OFAC) have issued proposed rules since December 2025, the Federal Reserve joined a five-agency customer identification proposal on 18 June 2026, and on 27 July 2026 the OCC sought approval for stablecoin issuer application forms (comments due 25 September 2026). The Act sets no penalty for the missed deadline; it takes effect on the earlier of 18 January 2027 or 120 days after final rules. The CLARITY Act remains stalled in the Senate: reported by the Banking Committee on 1 June 2026 with a substitute amendment, no cloture motion filed and no floor vote expected before the August recess; Senate Republicans circulated revised negotiating text on 22 July 2026. The SEC's three planned crypto rulemakings (token issuance safe harbour, broker-dealer capital and custody amendments, market structure) remained unpublished as of late July 2026.
Quick answers
Who regulates crypto licensing in United Kingdom and United States?
United Kingdom: Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers.. United States: No single federal crypto regulator. Federally, FinCEN (US Treasury) handles MSB registration and BSA/AML oversight. At the state level, each state's banking/financial-services department (e.g., NYDFS in New York, DFPI in California) issues and supervises money transmitter licences via NMLS. The SEC and CFTC separately assert jurisdiction over certain crypto activities (securities/commodities), the allocation of that jurisdiction is the subject of the pending CLARITY Act..
What licence do you need in United Kingdom compared with United States?
In United Kingdom the authorisation route is Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration.; in United States it is No single federal crypto licence. Fragmented dual-layer regime: (a) State-level Money Transmitter Licence (MTL), required in 49 states (all except Montana) plus DC, applied for via NMLS (Nationwide Multistate Licensing System) under each state's money transmission statute (31 states have adopted the Money Transmission Modernization Act, MTMA, in full or part as of Feb 2026); (b) Federal FinCEN Money Services Business (MSB) registration under the Bank Secrecy Act, via FinCEN Form 107, required for any business acting as a money transmitter/administrator/exchanger of convertible virtual currency. Some states have specific regimes (e.g., NY BitLicense from NYDFS, 23 NYCRR Part 200) as an alternative/superseding requirement.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full United Kingdom vs United States comparison?
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