What I do, and what it costs
Everything below is fixed-price and fixed-scope. There is no hourly rate, no retainer and no discovery call you have to sit through before you find out what something costs.
Start at the top of this page and stop at the rung that matches your problem. Most firms need one thing, not five.
Free — which regime and which category
Write to me in one line describing what your business actually does — whether you match orders, whether you hold client keys, whether any FX is involved, where your customers are. I will tell you which regime catches you, which category you fall under, and what that costs you in capital. No charge, no follow-up sequence, no call.
This is a five-minute answer and it is the answer most people need. tcb.group.888@gmail.com.
USD 79–149 — the readiness checklist
The written version of the checklist I run when I read a file, with the rule or regulation number behind every item. Full contents of each are here.
- Kenya — VASP Act 2025 and Legal Notice 134, USD 79. Transcribed from the gazette itself.
- Brazil — Res. BCB 519/520/521 and IN BCB 704, USD 79.
- United Kingdom — the FCA cryptoasset gateway, USD 149.
If your situation is straightforward, the checklist is enough and you will not need to speak to me. I would rather that than sell you something larger.
USD 500 — the 48-hour gap check
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. Two working days from the returned questionnaire; refunded in full if late. Book it.
USD 2,500 — the Readiness File
The full version. Category determination with the reasoning written out, the capital and liquidity calculation done properly — including Kenya's regulation 85(6) multi-activity rule, which is highest-category plus fifty per cent for each additional activity and is almost always got wrong — a document-by-document gap list, and a remediation plan in the order the items have to be fixed. Five working days. Book it.
USD 6,500–9,500 — the documents themselves
Kenya: the Nine-Policy Pack — USD 9,500
Regulation 6(2)(f) of Legal Notice 134 requires nine board-approved operational policies. Most of the market is still working from the March 2026 draft, which required four. The five nobody has budgeted for are data protection and privacy, market conduct, consumer protection, conflict of interest, and business continuity and disaster recovery.
Each policy needs a board meeting to approve it. There are fewer than ninety days to 4 November 2026. This is the largest single workstream in a Kenyan file and it is the one most commonly under-scoped.
Drafted for your business rather than templated, and written against the Kenyan instruments a reviewer actually has in mind — POCAMLA and the POCAML Regulations 2023 including the regulation 12 restriction that your MLRO cannot be the internal auditor or the CEO, the Data Protection Act 2019, the Computer Misuse and Cybercrimes Act 2018, the Consumer Protection Act 2012, the CBK Risk Management Guidelines, and for CMA categories the Corporate Governance and Conduct of Business Regulations 2011. Supplied with a board paper and a draft approval minute for each policy, plus a retention schedule covering every one of the five places LN 134 imposes the seven-year rule and the section 44(1) real-time read-only access obligation that is usually missed.
Ten working days. Book it.
Brazil: the Anexo IV Assurance Readiness Inventory — USD 6,500
IN BCB 739 added a reasonable assurance report by a CVM-registered independent auditor. Contrary to most published accounts it is not a Phase 1 item — article 9 was untouched. It sits in Phase 2 under article 10, X, and in the new-entrant route under article 5, XV. That is worse rather than better: the clock is sixty days from a favourable Phase 1 decision, which is a date you do not yet know.
We inventory what assurance your institution already holds against each of the eight heads of opinion in Anexo IV, apply the article 1 §1 scope carve-out — which turns on whether you were trading on 2 February 2026 — and the §2 twelve-month look-back, and return a gap list scoped tightly enough to put in front of an auditor. Seven working days. Book it.
United Kingdom: Policy Set and SM&CR Mapping — USD 9,500
The policy set an FCA case officer will ask to see, drafted against your activity heads under RAO articles 9M to 9Z11, plus the SM&CR work: senior management functions, prescribed responsibilities, statements of responsibilities and the responsibilities map, ready for 25 October 2027. If your activity heads are not yet settled, that determination comes first and is included. Ten working days. Book it.
USD 1,500 a month — regulatory monitoring
A short written note whenever something material changes in your regime, read off the primary instrument rather than the press, saying what it changes in your file and what you now have to do. Nothing is sent when nothing changes — I do not publish a weekly email for the sake of it. Includes free updated editions of every checklist. Subscribe, cancel any time.
For law firms, consultancies and associations
White-label licence
Licence to reproduce, rebrand and distribute the checklists and policy templates under your own name, to unlimited clients or members, for twelve months. Editable source files, every updated edition during the term, and attribution is not required — put your name on it and never mention mine.
- One jurisdiction — USD 6,000 a year
- All three, plus any added during the term, including the anchor API — USD 18,000 a year
If you would rather I prepared a co-branded version than hand you source files, say so and I will.
Regulatory Anchor API — USD 499 a month
Read access to the store behind everything above: capital and liquidity tables, required policy lists, fee schedules, deadlines and open items, per jurisdiction. Every row carries its source class and the primary-instrument URL it was transcribed from, so your product can distinguish instrument text from reporting of it — which is the distinction that matters and the one nobody else exposes.
JSON over HTTPS, keyed, with a changed-since endpoint. For RegTech products, compliance platforms and internal tooling. Subscribe.
What I am, plainly
A sole practitioner based in Okinawa, Japan. I hold no Kenyan, Brazilian or United Kingdom professional qualification, I am not a law firm, and none of this is legal advice or a substitute for local counsel. What I do is the operational readiness work that sits before the legal work — reading the primary instrument, mapping it against what a firm actually has, and writing the documents. Liability on every engagement is capped at the fee paid, and every deadline above carries a refund if I miss it.
If you are not sure which rung you are on, write the one line. That is free and it is usually enough to tell.