AML Crypto Perimeter Guide

Do You Need to Register for AML Supervision?

The money laundering perimeter explained — for financial, crypto and professional-services firms.

Three questions to place yourself on the right side of the line

Who supervises what: FCA, HMRC, professional bodies

The crypto MLR-to-FSMA transition and the 2027 commencement


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AML & Crypto Perimeter Guide

supervisor map · self-check · crypto transition


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Three questions that place you

Trading in a supervised sector without AML registration is a criminal offence — and registration failures are the most common trigger for penalties. The hard part is rarely the form; it’s knowing whether you’re in scope at all, and who supervises you.


1 Are my activities in scope?

Whether your activities fall within the defined sectors the MLRs capture.


2 Am I already supervised?

FCA, Gambling Commission or a professional body — many firms are supervised without realising it.


3 Who is my supervisor?

Usually FCA or HMRC — and some firms must deal with both.


Crypto firms: two regimes in transition

If you provide cryptoasset services, you’re mid-way through the biggest change since crypto AML registration began. The dates — and one trap most firms miss — matter now.


Now

MLR registration with the FCA remains the route to trade; allow time for determination.


30 Sep 2026 – 28 Feb 2027

FSMA authorisation application window opens for cryptoasset firms.


25 October 2027

New FSMA cryptoasset regime commences; unauthorised regulated activity risks the general prohibition.


There is no automatic conversion from MLR registration to FSMA authorisation. Every firm must make a fresh application — including those already registered or authorised for other activities.


Confirm your perimeter before you trade

We map every revenue activity against the MLRs and the regulated-activities perimeter, confirm your supervisor, and — for crypto firms — manage the MLR-to-FSMA transition end to end.


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This guide is general information about the UK AML registration perimeter as at 2026 and is not legal or regulatory advice for your specific circumstances. Scope questions turn on the detail of your business model; for advice tailored to your firm, speak to us directly.


Compliance Consultant

UK 0800 689 0190 · Int’l 0208 243 8620 · complianceconsultant.org


© Compliance Consultant. Trading name of UK Compliance Consultant Limited. All guidance is general information and subject to a final compliance-oversight review before reliance.

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