The three readiness checklists — Kenya, Brazil, United Kingdom
I keep one working document per regime. Each is the checklist I actually run when I read someone's file, written out with the rule, regulation or article number behind every item. They are not summaries of the news, and they are not marketing documents with a table of contents.
Three things are true of all of them. Every figure is marked with whether it comes from the instrument itself or from reporting of it. Every point that is genuinely still open is marked open rather than guessed at. And where a widely-repeated claim in the market is wrong, the document says so and shows the text.
Kenya — VASP licensing under the Act of 2025 and Legal Notice 134
13 pages. Transcribed from the gazette itself — Kenya Gazette Supplement No. 185 (Special Issue 4253), Legislative Supplement No. 103, Legal Notice No. 134 of 22 July 2026, made on 3 July 2026. That matters here more than it usually would: the Kenya Law record page for LN 134 carries no HTML body, the schedules exist only inside the PDF, and most of the figures circulating in this market are therefore reporting rather than text. Some of what is circulating is not reporting of the gazette at all — it is the March 2026 draft, which differs materially.
- The Fifth Schedule in full — paid-up capital and the liquid capital column, all ten categories. The 8 per cent limb, and where it overtakes the floor.
- Regulation 85(6), the multi-activity rule: highest-capital category plus fifty per cent for each additional activity. Not the sum. Not the highest alone. Worked example.
- The nine operational policies under reg. 6(2)(f), verbatim. The four-item list still in circulation is the draft.
- Regulation 88 on insurance — which is not in the capital schedule, whatever you have been told.
- The First Schedule fees in full, including the seven-band turnover scale for payment processor renewal and the approval fee that catches a post-licence cap table change.
- A draft-versus-gazette comparison table, so you can tell in one page whether the analysis you are holding is the law or its predecessor.
USD 79. Updated edition free when the application window opens.
Brazil — PSAV authorisation with the Banco Central do Brasil
13 pages. Built on the BCB normative texts, cross-checked against the DOU.
- The three modalities under Res. BCB 520 art. 4, decided by function rather than branding — and why an exchange holding client keys is a corretora.
- Why R$10.8m–R$37.2m is a calculation and not a price list, and why published worked examples disagree with each other and with the regulator.
- The Phase 1 set due 30 October 2026, and the Phase 2 set on its 60-day clock.
- IN BCB 739, stated correctly. It did not add the reasonable assurance report to Phase 1 — article 9 was untouched. It added art. 5 XV, art. 10 X and Anexo IV. The report is a Phase 2 item, which is worse rather than better for your timetable.
- The eight heads of opinion in Anexo IV, the §1 scope carve-out keyed to whether you were trading on 2 February 2026, and the §2 twelve-month look-back — the only timing lever the norm offers.
- What happens on refusal: 30 days to cease, 15 days to dissolve or change object.
USD 79. Updated edition free as the position develops.
United Kingdom — the FCA cryptoasset authorisation gateway
11 pages. Every requirement tied to a rule, an article number or a published FCA statement.
- The seven activity heads at RAO articles 9M to 9Z11 — and why there is no activity called a "qualifying cryptoasset exchange".
- Reg. 53 saving provision versus reg. 56 temporary exemption: which of the three outcomes you land in.
- The permanent minimum requirement by activity, why the highest applies rather than the sum, and how own funds is actually built.
- SM&CR from 25 October 2027, and the eight failure modes the FCA has published.
- What is still not final, including the application fee, with the date the answer is due.
USD 149. Updated edition free when the September 2026 fee notice and the autumn perimeter guidance land.
If your situation is not straightforward
The 48-hour gap check is USD 500. I read what you have, map it against the regime, and send back a written list of what is missing and in what order to fix it, in two working days. If the report is not delivered within 48 hours of the completed questionnaire coming back, the fee is refunded in full.
If your situation is straightforward, the checklist is enough and you will not need to speak to me. I would rather you used one and never wrote again than bought something you did not need.
Before you buy anything
Write to me in one line describing what your business does, and I will tell you which regime and which category I think you fall under, and what that costs — at no charge. That is a five-minute answer, not a project. tcb.group.888@gmail.com.
These documents organise publicly available regulatory information. They are not legal advice and do not create a professional relationship. I am a sole practitioner based in Japan and hold no Kenyan, Brazilian or UK professional qualification; this is an operational readiness view. Liability is limited to the fee paid.