What we think

Executive Summary The global regulatory environment in March delivered an asynchronous, aggressive push toward integrating Crypto-Asset Service Providers (CASPs) into the traditional financial services (TradFi) perimeter. The sheer volume and severity of cross-jurisdictional updates—ranging from the European Union’s Digital Operational Resilience Act (DORA) and MiCA enforcement preparations, to the UK’s FSMA regime transition and the FATF’s targeted crackdown on offshore liqu

Executive Summary Yesterday, the UK Financial Conduct Authority (FCA) hosted its second authorisations webinar outlining its supervisory expectations for crypto-asset firms transitioning to the new Financial Services and Markets Act (FSMA) Part 4A authorisation regime . The FCA’s overarching message to the industry was unequivocal: do not wait for the new regime to build your compliance framework.  The transition from the existing Money Laundering Regulations (MLR) to FSMA wi

Executive Summary February 2026 represented a structural inflexion point for the global digital asset industry. Regulatory frameworks across major jurisdictions—from the Parliamentary enactment of the UK’s Final Crypto Regime Statutory Instrument to the EU’s AMLA data collection initiatives and the operational onset of the U.S. Treasury’s broker tax reporting—have definitively transitioned from conceptual rulemaking to active enforcement and structural market integration. For

Part 1: SwanFS Report on UK Progress to Implement Cryptoasset Regulation 1. Executive Summary The UK Financial Conduct Authority (FCA) is finalising a comprehensive, FSMA-based regulatory regime for cryptoassets. Transitioning from a limited perimeter focused on Anti-Money Laundering (AML) and financial promotions, the FCA is implementing a full-scale conduct, prudential, and market integrity framework under the Designated Activities Regime (DAR) and the expanded regulatory p

1. Executive Summary The Financial Conduct Authority (FCA) has concluded its introductory webinar outlining the definitive roadmap for the UK’s transition from the limited Money Laundering Regulations (MLR) to a comprehensive Financial Services and Markets Act (FSMA) regime. The headline message is critical:  The regulatory bar has been raised significantly. There is no automatic transfer (“grandfathering”)  for currently registered firms. Every Crypto Asset Service Provider

1. Executive Summary December 2025  marked a definitive structural shift in the global crypto landscape from regulatory containment  to regulated integration . For Crypto-Asset Service Provider (CASP) business models, the era of arbitrage is effectively closed. The new operating reality is characterised by a “Great Divergence” : Expansion:  Expanded addressable markets and banking access in the US , UK , and Japan . Contraction:  Sharply rising capital and operational costs i

1. Executive Summary: 1. The Macro-Strategic Shift: From “Move Fast” to Industrial Policy The EU’s “Market Integration and Supervision” package (MiCA 2.0) represents a fundamental pivot from consumer protection to geopolitical industrial strategy. Grounded in the Draghi Report’s call to close the EU’s investment gap, this regulation aims to “sanitise” the crypto sector to mobilise household savings. Strategic Implication: The era of “move fast and break things” is foreclosed.

Executive Summary The Royal Assent granted to the Property (Digital Assets etc.) Act 2025 on December 2, 2025, marks a significant turning point in the history of English private law. Although this legislation is relatively brief, it has a profound impact on the United Kingdom’s legal and commercial landscape, effectively resolving a long-standing doctrinal stalemate that had threatened to separate the common law from the realities of the modern digital economy. By formally b

Executive Summary November 2025 represents a watershed moment in global financial regulation, characterised by a stark bifurcation in regulatory philosophy between the Atlantic powers. In the European Union, the transition to granular operational enforcement reached its zenith with the designation of Critical ICT Third-Party Providers (CTPPs) under the Digital Operational Resilience Act (DORA) and the finalisation of technical standards under the Markets in Crypto-Assets Regu

Executive Summary The UK’s financial services sector is undergoing a major regulatory shift as Cryptoasset Service Providers (CASPs) move from limited AML registration to full authorisation under FSMA. This “re-platforming” transforms the industry. This report provides a detailed analysis, clarifies misconceptions, highlights omissions, and redefines strategic directions for firms in this space. The analysis based on consultation papers and HM Treasury drafts shows this trans

Introduction: A ‘Multi-Money’ System and the Grand Bargain: Contextualising the November 2025 Consultation The Bank of England (BoE) consultation paper (CP) published on 10 November 2025, ‘Proposed regulatory regime for sterling-denominated systemic stablecoins’, represents a pivotal and pragmatic evolution in the United Kingdom’s approach to digital assets. This document is not a preliminary discussion; it is a mature, highly detailed, and commercially aware proposal. It has

I. Executive Summary This week’s developments signal an evolution in the regulatory environment, shifting from theoretical risk to tangible enforcement actions and notable strategic divergence among key jurisdictions. For Crypto Asset Service Providers (CASPs), the global landscape now presents three primary areas of focus that merit careful consideration for our operational, product, and legal strategies. Enforcement and AML/CTF Scrutiny.  The €21.46 million fine imposed by

Executive Summary October 2025 marked a material shift in the regulatory landscape for the crypto-asset industry, moving from high-level principles to binding technical implementation. The fragmented, principles-based guidance of the past has been supplanted by a wave of detailed, binding Regulatory Technical Standards (RTS), supervisory Q&As, and thematic reports. This transition fundamentally alters the operational, prudential, and economic landscape for Crypto-Asset Servic

Executive Summary 2026 marks a pivotal year for EU Crypto-Asset Service Providers (CASPs), marking the culmination of a multi-year effort to establish comprehensive regulation for digital assets. The transitional “grandfathering” period under MiCA, as per Article 143(3), ends on July 1, 2026, removing legacy buffers and implementing a uniform licensing and conduct system across the Union. Meanwhile, the Digital Operational Resilience Act (DORA), which has been effective since

Executive Summary 2025 marks a pivotal shift for digital assets and financial markets, moving from regulatory development to strict...

Executive Summary September 2025 marked a critical phase in the maturation of the European Union’s digital asset regulatory landscape....

I. Executive Summary The FCA's guidance shifts the standards for firms seeking authorisation or registration, marking a strategic change...

Executive Summary This report analyses the potential implications of the recent UK cabinet reshuffle on the nation's digital market...