TK Global OS — Regulatory notesCryptoasset licensing: United Kingdom, Kenya, Brazil

Regulatory notes

Working notes on cryptoasset licensing in the United Kingdom, Kenya and Brazil. Every figure is tied to a rule, an article number or a published regulator statement. 11 notes.

UK 11Kenya 5Cross 3Brazil 3 All

The audited accounts dependency that decides your filing date

The FCA fixed overheads requirement runs off prior-year audited expenditure. What is deductible, when the FOR overtakes the PMR, and the audit myth.

UK · 2026-08-13

What the FCA expects in a cryptoasset wind-down plan

The application form never says wind-down plan. CRYPTOPRU 7.2.6R does. Where the UK crypto wind-down obligation actually sits, and what it costs.

UK · 2026-08-13

The seven cryptoasset activity heads, and why the article numbers matter

SI 2026/102 inserted seven cryptoasset activities into the Regulated Activities Order at articles 9M to 9Z11. Why the article numbers matter.

UK · 2026-08-12

The FCA cryptoasset application fee has not been published yet

PS26/14 deferred the FCA cryptoasset application fee to the September 2026 Handbook Notice. The GBP 11,260 figure is the MLR fee, not the FSMA one.

UK · 2026-08-12

Eight reasons FCA cryptoasset applications get sent back

The FCA has published its own diagnosis of poor-quality cryptoasset applications. Eight failure modes, in the regulator words, and what a good file looks like.

UK · 2026-08-12

What capital you need for FCA cryptoasset authorisation, by activity

PS26/12 fixed the permanent minimum requirement per cryptoasset activity: GBP 75,000 to GBP 750,000, with no transitional relief.

UK · 2026-08-12

Regulation 53 and 56: what happens if you file late, or not at all

Regulation 53 lets a firm with an undetermined application keep trading. Regulation 56 is run-off: pre-existing contracts only, no new UK customers.

UK · 2026-08-12

SM&CR for cryptoasset firms: you are almost certainly a Core firm

PS26/13 applies SM&CR in full to cryptoasset firms from October 2027. Enhanced thresholds are GBP 100bn and GBP 20bn, so almost every firm is Core.

UK · 2026-08-12

Article 9N vs article 40: are you in scope of the UK crypto regime?

Article 9N covers crypto safeguarding; SI 2026/102 narrows article 40 to exclude cryptoassets. The UK custody perimeter, exclusions and reach.

UK · 2026-08-11

Why your FCA MLR registration will not carry over to FSMA

The FCA has confirmed there is no automatic conversion from MLR registration to FSMA authorisation. What UK crypto firms must do, and by when.

UK · 2026-08-10

The FCA FSMA cryptoasset gateway (opens 30 September 2026)

The FCA cryptoasset gateway opens 30 September 2026 and closes 28 February 2027. The FSMA regime begins 25 October 2027. MLR does not convert.

UK · 2026-08-09

Get the note when something actually changes

The UK gateway, Kenya's VASP Act and Brazil's BCB regime. Only when a rule, date or figure moves — and primary sources are always marked separately from press reporting.