Professional & Financial Services Financial services regulation UK-wide

Register a money service business or crypto-asset business for AML supervision

How a money service business registers with HMRC, and how a cryptoasset business registers with the FCA, for anti-money laundering supervision under the Money Laundering Regulations 2017. Covers which regime applies to you, the fit-and-proper test, registering before you trade, the offence of operating unregistered, and the financial promotions rules for qualifying cryptoassets.

Guide summary

Register with HMRC or the FCA for anti-money laundering supervision before you start trading. If you transmit money, run a bureau de change or cash cheques, register with HMRC. If you provide cryptoasset exchange or custodian wallet services, register with the FCA. Trading without registration is a criminal offence.

  • Register with HMRC before trading if you transmit money, exchange currency or cash cheques
  • Register with the FCA before trading if you run a cryptoasset exchange or custodian wallet
  • Pass the fit-and-proper test – HMRC or FCA checks you and your business are suitable
  • You can be on both paths if you do both money service and cryptoasset activities
  • Trading first and registering later is a crime – register before you start
  • Keep customer records for 5 years after the business relationship ends
  • Report suspicious activity to the National Crime Agency as soon as possible
  • Train all staff on anti-money laundering rules when they start and regularly after
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If your business handles other people's money or cryptoassets, you may need to register for anti-money laundering (AML) supervision under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 before you start trading. Two of those activities have their own registration gateway, and they go to different regulators.

Work out which path applies to you:

  • If you carry on money transmission, currency exchange (a bureau de change), or cheque cashing, and you are not already supervised by the Financial Conduct Authority (FCA), you are a money service business and you register with HMRC.
  • If you are a cryptoasset exchange provider or a custodian wallet provider, you register with the FCA.

You can be on both paths if you do both kinds of activity. This guide covers each path. If your only activity is regulated payment services or holding deposits, you need a different permission - see the related guidance at the end.

The shared AML baseline

Whichever path you are on, registration puts you under the Money Laundering Regulations 2017. The Regulations set the controls you must have in place from the day you start trading - a risk assessment, a nominated officer, customer due diligence, ongoing monitoring and record keeping. The registration step below sits on top of these duties; it does not replace them.

Path A - money service business (register with HMRC)

HMRC is the AML supervisor for money service businesses that are not otherwise supervised by the FCA. You must be registered before you begin to trade. Trading first and registering later does not put things right - the breach has already happened. As part of registration, the business and the people responsible for it must pass a fit-and-proper test, and HMRC can refuse registration if you do not meet it.

Path B - cryptoasset business (register with the FCA)

A cryptoasset exchange provider or custodian wallet provider must register with the FCA for AML purposes before carrying on business. The FCA assesses your beneficial owners, officers and managers and whether your AML systems and controls are adequate. Be conservative about what registration gives you. It is AML supervision, not authorisation to provide regulated financial services, and it is not a full prudential regime.

Separately, if you promote qualifying cryptoassets to UK consumers, that promotion is caught by the financial promotion restriction in section 21 of the Financial Services and Markets Act 2000. The promotion must be made or approved by an authorised person, or fall within an exemption. This applies even where your only registration is for AML. The wider regime under the Financial Services and Markets Act 2023 is still being built out, so the binding requirements for most firms today remain AML registration and the financial promotion rules.

  1. 1

    1. Confirm which regime applies before you do anything else

    Decide whether you are a money service business (money transmission, currency exchange or cheque cashing, and not FCA-supervised) or a cryptoasset business (exchange provider or custodian wallet provider). This decides whether you register with HMRC or the FCA. If you do both kinds of activity, you must register for both.

  2. 2

    2. Get your AML controls in place first

    Carry out your business risk assessment, appoint a nominated officer, and write the customer due diligence and monitoring procedures the Money Laundering Regulations 2017 require. Registration assesses whether these systems and controls are adequate, so build them before you apply.

  3. 3

    3. Prepare for the fit-and-proper test

    Identify the beneficial owners, officers and managers the regulator will assess, and gather the information they need on each person. HMRC and the FCA can refuse registration where the fit-and-proper requirement is not met.

  4. 4

    4. Register before you start trading

    Apply to HMRC (money service business) or the FCA (cryptoasset business) and wait for confirmation before you carry on the activity. Operating without the required registration is a criminal offence, so do not begin trading on the assumption that approval will follow.

  5. 5

    5. If you promote cryptoassets, check the financial promotion rules

    For qualifying cryptoassets, make sure any promotion to UK consumers is made or approved by an authorised person, or falls within an exemption, under section 21 of FSMA 2000. Breaching the financial promotion restriction is a separate offence.

  6. 6

    6. Keep your registration current

    Tell your supervisor about changes to your business, owners or controllers, keep your AML controls under review, and watch for the wider cryptoasset regime being developed under FSMA 2023 if you are a crypto firm.

What to do next

Once you are registered, your obligation is to operate your AML controls in practice and keep them up to date. If your activities go beyond AML-supervised business - for example providing regulated payment services or e-money - you will need separate FCA authorisation or registration under a different regime. Use the official sources below to start your application and to confirm the current position for cryptoasset firms.

Official sources

Statutory sources and regulator guidance for registering for AML supervision.