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THIS week’s crypto corner focuses on the clarity being brought to the industry by the Financial Conduct Authority and its most recent consultation paper.
The paper puts a strong emphasis on certified people and outcomes over technology, flipping the narrative from tech bros to Wall Street.
Certifiable people and outcomes have been at the heart of the Moneybrain ecosystem from the ground up.
Here are a few ways in which our work aligns with the consultation paper:
Consumer duty is ever more important as the crypto industry moves towards an outcomes-based framework, such as lending. Our UK savings, lending, ISA and payments businesses already operate under consumer duty, and UK crypto is being aligned upwards to that standard.
Fiat is client money. Crypto requires explicit safeguarding. The FCA draws a clear line. We deliberately separate FCA-regulated UK fiat activity from our Jersey VASP digital-asset layer to keep this boundary clean and transparent.
Directors’ and employees’ SMCR accountability is explicitly reinforced, emphasising that crypto firms must have named, UK-approved senior managers.
Although Moneybrain is based in Jersey, we have the necessary requirements in place through our sister company to meet this condition. The takeaway is that real, robust governance and real accountability, not anonymous structures or shortcuts, are at the heart of the FCA’s consultation paper.
At Moneybrain, our UK-regulated entities, SMCR-approved senior managers and publicly registered MLROs already operate to those standards, and we will engage constructively
with the FCA as the regime is finalised.








