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| Dimension |
Pinned 🇬🇧 United Kingdom Free in full Verified 2026-07-15
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🇺🇸 United States
partly open
Verified 2026-07-15
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|---|---|---|
| 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 11,150 (Category 6, 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 (renumbered from G.23): minimum GBP 2,229 for 2025/26 plus GBP 15.13 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. The FCA published its 2026/27 fees policy statement PS26/14 on 2 Jul 2026; cryptoasset periodic fee-block detail is still expected in a September 2026 Handbook Notice, with nothing published early as of 15 Jul 2026. 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. | GENIUS Act implementing rules remain at proposed-rule stage as the 18 July 2026 statutory deadline approaches. The Office of the Comptroller of the Currency (25 February 2026), the FDIC (application procedures from 16 December 2025 and prudential standards from 7 April 2026), the National Credit Union Administration (11 February and 18 May 2026) and Treasury with FinCEN and OFAC (illicit-finance rules 8 April 2026, state-equivalence principles 1 April 2026) have all issued proposed rules, but none has yet finalised one. The Federal Reserve joined a five-agency proposal on customer identification programme requirements on 18 June 2026, alongside FinCEN, the OCC, the FDIC and the NCUA, but as of 15 July 2026 it has not issued its own implementing rule covering capital, liquidity and risk management for state member banks, the equivalent of the rules the other banking agencies have already proposed. The GENIUS Act sets no fallback if the 18 July deadline is missed; the effective date defaults to 18 January 2027 regardless of rulemaking progress. Separately, the CLARITY Act on market structure remains stalled in the Senate: it was reported out of the Senate Banking Committee with a substitute amendment on 1 June 2026 and sits on the Senate Legislative Calendar, but no cloture motion has been filed and three disputes are unresolved, over crypto ethics and insider-trading language, a law-enforcement carve-out, and a stablecoin-yield loophole. The Senate returned from recess on 13 July 2026, leaving roughly three working weeks before the chamber's August recess as the last realistic window this session. The SEC's three targeted crypto rulemakings, a capital-formation safe harbour for token issuers, broker-dealer capital and customer-protection amendments, and market-structure amendments, were flagged for a July 2026 proposal on the SEC's regulatory agenda but had not been formally published as of 15 July 2026 and remain under White House regulatory review. |
| 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. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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