What we think

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

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

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....

Executive Summary The year 2025 represents a watershed moment for digital asset regulation in the United States, marked by the...

Executive Summary The first half of 2025 represents a pivotal inflexion point for the digital asset sector, characterised by a structural...

Global Regulatory Developments: July Executive Summary July marked a period of intense regulatory activity across the globe,...

The European Banking Authority (EBA) has released its work program for 2025, signalling a significant shift in the regulatory landscape...

The European Securities and Markets Authority (ESMA) has set an ambitious agenda for 2025, with significant implications for investment...

The European Securities and Markets Authority (ESMA) has set an ambitious agenda for 2025, with a work program that covers a wide range...

The digital landscape underwent significant changes in 2024 as regulators worldwide tightened their control over the industry. Every...

The financial services landscape is grappling with various operational challenges, from cyberattacks and third-party failures to the...

The world of Decentralised Finance (DeFi) is rapidly evolving, pushing the boundaries of traditional finance and challenging existing...

The ECB draft guide emphasises the critical role of robust governance and a strong risk culture in ensuring the safety and soundness of...

The European Securities and Markets Authority (ESMA) has released a series of Q&A updates regarding the Markets in Crypto-Assets (MiCA)...