Upper Tribunal considers the application of the MLRs to a cryptoasset exchange provider and comments on FCA procedures
July 28, 2022
The business of Vladimir Consulting Limited (VCL) involved trading in cryptocurrency such as bitcoin on peer-to-peer exchanges which provide a market place for sellers and buyers of cryptocurrency. The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) were amended with effect from 10 January 2020 to require cryptoasset exchange providers such as VCL to be registered with the FCA. VCL applied to the FCA in September 2020 and moved into a temporary registration regime pending the determination of its application.