The Financial Conduct Authority (FCA) provided a non-exhaustive list of steps that companies should take in order to prepare their application for registration.
Before preparing the application
Establish if they will be carrying out in-scope cryptoasset activity
Consider seeking independent legal/compliance advice as part of preparing an application
Review the relevant information on the FCA’ webpages as well as the registration form
Appoint a Money Laundering Reporting Officer (MLRO)/ Nominated Officer with relevant knowledge, experience and training as well as a level of authority, independence and sufficient access to resources and information. The FCA will assess the fitness and propriety of the MLRO/Nominated Officer.
When preparing the application
Include all required information in the business plan, this includes but is not limited to : details of the business model, roles and responsibilities of business partners (such as service providers, brokers, introducers, sub-custodians and outsourcing partners), sources of liquidity, detailed customer journey…
Comprehensive and accurate description of products and services (e.g. a cryptoasset token vetting policy, detailed description of how dependent it is on external ecosystems for liquidity, custodian services and underlying smart contracts/DeFi implementations.) .
Demonstrate a thorough understanding of the risks from dealing in cryptoassets and design a business wide risk assessment (BWRA) that is tailored to their business model.
Implement policies, systems and controls to appropriately manage and mitigate the risks identified in the BWRA
Have in place an effective framework for transaction monitoring and blockchain analysis
Provide complete information regarding its outsourcing arrangements within and outside the group, as well as within and outside the UK
Provide evidence staff training material tailored to its particular business model and associated AML/CTF risks along with its annual training plan
Ensure that the Suspicious Activity Reporting policy fully covers the company cryptoasset-related activities