Finance in a Cryptoasset Firm Under the FCA Regime

Cryptoasset finance is the newest corner of UK regulated finance and the one where the gap between what firms need and what the market supplies is widest. The work combines conventional financial control with obligations that resemble client money without being it, valuation questions with no settled practice, and a regulatory perimeter that has moved repeatedly — and is now moving decisively, with the FCA’s authorisation gateway open and a full regime due to commence in October 2027. This guide sets out what a Financial Controller actually owns in a cryptoasset firm, where the difficulty concentrates, what transfers from adjacent sectors, and what the roles pay.

A note on scope: the regulatory position for cryptoassets in the UK has developed considerably and continues to. This guide covers the finance function’s practical remit rather than the regulatory position in full, which should be taken from the FCA’s cryptoasset pages and the firm’s own advisers. Where we summarise the new regime below, it is to show what it means for finance.

The perimeter question comes first

As with payments, everything follows from what the firm is actually registered or authorised for, and it is regularly assumed rather than established. A firm may be registered for anti-money-laundering supervision as a cryptoasset business, may hold e-money or payments permissions for the fiat side of its operation, may be authorised for regulated activities where its products fall inside the perimeter, or may sit largely outside it.

Each produces a different set of finance obligations, and the same group frequently holds several. The first thing an incoming FC should establish — and the first thing an employer should state in a job specification — is which entity holds which permission and what follows from each.

The new FCA regime and what changes for finance

HM Treasury’s Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 create new regulated activities for cryptoassets under FSMA, and in June 2026 the FCA published its final policy statements, PS26/9 to PS26/13. Between them they cover:

• admissions and disclosures, and a market abuse regime for cryptoassets (PS26/9);
• issuing qualifying stablecoins, with backing assets safeguarded under a new CASS 16 (PS26/10);
• trading platforms, dealing and arranging intermediaries, lending and borrowing, staking, and cryptoasset custody under a new CASS 17 (PS26/11);
• prudential requirements in two new sourcebooks, COREPRU and CRYPTOPRU (PS26/12);
• how the rest of the Handbook applies, including the Consumer Duty, conduct of business rules, SM&CR, operational resilience and financial crime (PS26/13).

The gateway for applications opened on 30 September 2026 and the application window closes on 28 February 2027; the regime commences on 25 October 2027. Until then the existing anti-money-laundering registration regime continues. Registration does not convert into authorisation: firms already registered still need to apply, and the FCA explains on its page about how the gateway will operate that firms applying within the window may keep operating while their application is decided, while later applicants face much tighter limits.

For the finance function this is the biggest change the sector has seen. A firm that has been an AML-registered business with a light finance process becomes, on authorisation, a firm with a capital requirement, client-asset rules, regulatory reporting and senior managers accountable under SM&CR. The application itself needs financial projections, capital calculations and a description of the controls — work that lands on the FC, usually in parallel with the day job. Our overview of what the FCA expects from your finance function describes the standard authorised firms are held to.

Reserve and client asset reconciliation

The defining operational discipline, and the one that most resembles client money without being governed by the same rules.

Where a firm holds cryptoassets or fiat on behalf of customers, someone has to demonstrate daily that what is held matches what is owed. That means reconciling on-chain balances across wallets and custodians, exchange and venue balances, and fiat held at banks or safeguarding institutions against the customer liability recorded in the firm’s own systems.

The difficulty is that these live in entirely different places: a blockchain explorer, a custodian’s portal, an exchange API and a ledger, none of which agree on timing or granularity. Our guide to stablecoin reserve reconciliation covers the discipline in detail, and it applies with variations across the sector.

Where the fiat side sits in an authorised payments or e-money entity, safeguarding obligations attach to it directly — and the reconciliation between the two sides of the business is frequently where errors accumulate.

The new regime moves this discipline closer to client money in form as well as spirit. Stablecoin backing assets fall under CASS 16, held on statutory trust, and the FCA’s final rules require issuers to reconcile the backing pool daily against tokens in circulation. Firms safeguarding customers’ cryptoassets fall under CASS 17. Finance teams that have worked with CASS reconciliations will recognise the structure: defined internal and external checks, a breaks process with escalation, and an evidence file an auditor can test.

Valuation and accounting

The technical half, and the area with least settled practice.

Measurement. How cryptoassets held are classified and measured depends on the nature of the holding and the applicable framework, and it is a genuine judgement rather than a lookup. The FRC frameworks were not written with these assets in mind, which is why the treatment needs documenting carefully — see writing technical accounting memos.

Own versus customer assets. The distinction that matters most on the balance sheet, and the one auditors examine first.

Revenue recognition on trading spreads, transaction fees, staking or yield arrangements and subscription products — each with its own timing question.

Volatility. Positions that move materially between the reporting date and the sign-off date, which affects both the accounts and the capital position where one applies.

And the audit. Auditing existence of on-chain assets is a genuinely different exercise, and firms should expect their auditor to want evidence of control over keys as well as of balances. Our guide to audit preparation for Financial Controllers covers the groundwork that makes a first regulated audit manageable.

Capital under CRYPTOPRU

Authorised cryptoasset firms will hold capital under the new prudential sourcebooks, COREPRU and CRYPTOPRU. The FCA’s final rules include specific treatments for cryptoasset exposures — for example, cryptoassets that cannot be prudently valued are deducted from capital — so valuation judgements now feed directly into the capital calculation as well as the accounts. The FC becomes the owner of a capital figure that must be monitored, reported and, if it falls towards its threshold, escalated. For finance professionals moving across from investment firms, the logic will be familiar from regulatory capital, the ICARA and IFPR; the detail is new, and should be taken from PS26/12 and the firm’s advisers.

What transfers into this sector

Three backgrounds produce credible candidates, and one does not.

Payments and e-money finance transfers best. Safeguarding discipline, daily reconciliation of money in flight, and settlement across parties the firm does not control are all directly applicable — our guide to e-money and payments regulation in fintech covers that ground, and hiring an FC for a payments firm sets out the profile.

CASS and client money transfers well for the same reason: the mindset that customer assets are not the firm’s, and the discipline of daily proof. Our introduction to CASS and client money explains the overlap.

Investment firm finance transfers where the firm holds regulated permissions and a capital requirement applies — which, once the regime commences, will be the case for every authorised cryptoasset firm.

A purely commercial background does not, and this is the sector where that matters most — because the firm is frequently young, the process does not exist, and there is nobody senior to check the judgements.

Where firms struggle

Reconciliation built in spreadsheets by one person. Universal in the sector and increasingly fragile as volumes grow.

Perimeter drift. A product changes, and nobody re-examines whether it has moved the firm’s regulatory position — a compliance question that finance frequently notices first because the money flows change.

Accounting judgements undocumented. Treatments applied consistently for two years with no memo explaining why, discovered at audit.

Growth outpacing control. The most common failure. Firms in this sector scale volume faster than almost any other, and the finance process that worked at launch stops working quietly.

And key-person concentration, more acute here than elsewhere because the person who built the reconciliation frequently also understands the wallets.

Treating authorisation as a compliance project. The application window runs to 28 February 2027, and much of what the FCA will want to see — projections, capital, client-asset controls, a credible finance function — is finance work. Firms that leave the FC out of the application, or hire one after submission, tend to find the gaps when the FCA asks questions. A fractional FC for an FCA-regulated firm is one way to cover the application without committing to a full-time hire too early.

What the roles pay

Cryptoasset finance typically prices at or above the wider regulated premium, for two reasons: the pool of people who have done it is small, and firms competing for them are frequently venture-backed with the ability to pay. Equity is commonly a meaningful part of the package, and the leaver provisions matter as much as the allocation — see our bonus and incentive benchmarks. Wider bands are in the regulated-firm finance salary guide, and why regulated finance roles pay more explains the premium. The figures are typical ranges, not fixed points; stage, funding and the permissions held move them considerably. Finance Director and CFO searches typically run with our sister firm FD Capital.

Specifying the role

Four points. State the permissions by entity — AML registration, e-money, payments, regulated activities, and whether the firm is applying through the new gateway — because it determines the obligations and reaches the right pool. Describe what is held and where: own assets, customer assets, custodial arrangements, exchange balances. Say whether the reconciliation exists and who built it; candidates worth hiring want to know whether they are running a process or designing one. And be honest about scale and stage — pre-revenue, scaling, or established changes the job entirely.

Qualification — ICAEW, ACCA or CIMA — is the baseline, and the adjacent-sector experience is what you are buying. Our cryptoasset and digital assets finance practice covers the search.

Senior manager functions sit with our sister firms. Under the new regime SM&CR applies to authorised cryptoasset firms, so compliance oversight (SMF16) and MLRO (SMF17) appointments are increasingly part of the same hiring plan; those searches run with SMF Capital. Our guide to understanding the FCA for finance staff is a useful primer for candidates crossing into the sector.

Frequently asked questions

Does an FCA AML registration count as authorisation under the new regime?

No. Registration does not convert automatically. Registered firms that want to continue after the regime commences on 25 October 2027 need to apply for authorisation; the application window runs from 30 September 2026 to 28 February 2027.

What does a cryptoasset Financial Controller own?

Typically the reconciliation of customer assets and fiat, valuation and accounting judgements, the audit, the capital calculation once authorised, and the finance input to the authorisation application and regulatory reporting.

Which background makes the best crypto FC?

Payments and e-money finance, followed by CASS and client money. Investment firm finance transfers where capital applies. A purely commercial background is the riskiest appointment in this sector.

Should we hire interim or permanent?

Many firms use an interim or fractional FC to get through the application and build the reconciliation, then hire permanently. Our page on interim versus fractional finance compares the options.