By CRYPTOVERSE Legal Consultancy
An FCA crypto application interview is an opportunity for the regulator to assess whether the people responsible for the business understand its activities, risks and controls.
Preparation should enable management to explain how the applicant will operate, who makes important decisions and what evidence supports the application. Memorising policies provides limited value if managers cannot explain how those policies work in practice.
The FCA’s general authorisation guidance expects applicants to be ready, willing and organised, able to articulate their regulatory obligations and open and honest throughout the assessment process. FCA
This article explains a practical approach to preparing directors, senior managers, compliance personnel and Money Laundering Reporting Officers for regulatory interviews and application discussions.
1. Identify Which FCA Process the Interview Concerns
Before preparing, establish whether the meeting relates to:
- Cryptoasset registration under the Money Laundering Regulations.
- A new authorisation application under the Financial Services and Markets Act 2000.
- A variation of permission by an existing FSMA-authorised firm.
- An individual’s fitness, propriety or proposed responsibilities.
- An optional pre-application discussion.
These processes have different purposes. A pre-application meeting should not be treated as an authorisation assessment or approval.
The FCA’s crypto authorisation gateway opened on 30 September 2026, with the relevant application period currently scheduled to close on 28 February 2027. Existing MLR registration does not automatically convert into FSMA authorisation; firms already authorised under FSMA need to apply to vary their permissions where appropriate. FCA
Confirm the meeting’s purpose, requested attendees, format and supporting material from the FCA’s invitation. Do not assume that every applicant will face the same interview or question sequence.
2. Understand What Management Competence Means
For the expanded crypto regime, the FCA identifies standards concerning the suitability of the business model, effective supervision, appropriate resources and the firm’s suitability. Its individual fitness and propriety assessment includes honesty, integrity and reputation, financial soundness, and competence and capability. FCA
A useful preparation question is:
Can each responsible individual explain the decisions, risks and controls within their remit, using evidence from this applicant?
For example, a director should be able to explain why the firm’s staffing and funding plans support its proposed services. A technology lead should be able to describe withdrawal controls and incident response. The MLRO should understand the firm’s financial crime exposure and escalation arrangements.
The depth of knowledge should reflect the person’s responsibilities. Management should also understand how its different functions connect.
3. Explain the Business Model Clearly
Begin preparation with a concise description of the applicant:
- Which legal entity contracts with customers?
- What products and services will it provide?
- Which customers and jurisdictions will it serve?
- How does it earn revenue?
- Which activities will other group entities or external providers perform?
- Where do fiat money and cryptoassets move?
- Who controls assets and authorises transactions?
Avoid relying on broad labels such as “exchange”, “broker” or “Web3 platform”. Those descriptions may conceal several distinct services.
For internal preparation, management should practise explaining one representative transaction from customer onboarding through execution, settlement and withdrawal. Identify each entity, system and decision point along the way.
A clear transaction explanation helps expose gaps that an organisational chart or business plan may miss.
4. Understand the Permission Analysis
Management should understand the relationship between the business model and the permissions requested.
A practical preparation exercise is to ask:
- What does the applicant actually do?
- Which requested permission covers that activity?
- What assumptions support the analysis?
- What limits will the business observe?
- Which future changes would require a fresh assessment?
For example, moving from introducing customers to executing transactions, or changing who controls customer withdrawals, may alter the relevant analysis.
Legal advisers can help explain complex perimeter questions. Management should nevertheless understand the conclusions that determine how its business may operate.
Keep current operations, proposed authorised operations and possible future products clearly distinguished throughout the discussion.
5. Prepare Each Person for Their Responsibilities
The following is a suggested preparation map, rather than a prescribed FCA attendance list.
| Role | Suggested preparation focus |
| Chief executive or executive director | Business strategy, permissions, resources, major risks and implementation decisions |
| Board member responsible for oversight | Challenge, reporting, conflicts, escalation and accountability |
| Compliance lead | Applicable requirements, monitoring, breaches and regulatory communications |
| MLRO | Financial crime risks, customer assessment, monitoring, investigations and suspicious activity escalation |
| Finance lead | Forecast assumptions, funding, liquidity and financial contingencies |
| Technology or security lead | Access controls, wallet architecture, testing, incidents and recovery |
| Operations or custody lead | Transaction processing, reconciliation, withdrawals and exception handling |
For each person, document their authority, reporting line, capacity and access to information.
In a group structure, test whether local management can explain which decisions it controls and which require group approval. Identify how disagreements or urgent risks would be escalated.
6. Prepare the MLRO for Detailed Questions
The FCA’s published MLR registration guidance expressly discusses MLRO interview competence. It expects appropriate cryptoasset knowledge, relevant skills and experience, sufficient capacity and manageable conflicts. It also assesses the oversight available to MLROs based outside the UK. These are MLR-specific expectations, which should be distinguished from the broader FSMA assessment. FCA
A practical MLRO preparation session should explore questions such as:
- Which financial crime risks are most significant for this business?
- How does customer risk affect onboarding and ongoing review?
- How are monitoring alerts investigated?
- What are the limitations of the selected screening and analytics tools?
- Who can challenge a commercial decision on financial crime grounds?
- How are unresolved alerts and control weaknesses escalated?
- How will the function cope with increased customer or transaction volumes?
Use the applicant’s actual framework to answer. Where operations have not commenced, explain the testing performed and distinguish simulated cases from live experience.
7. Practise Scenarios That Test Decision-Making
Scenario exercises can reveal whether responsibilities and escalation routes are sufficiently clear.
The following are illustrative preparation questions, not an official FCA question bank.
| Scenario | Questions to explore |
| A withdrawal generates a high-risk blockchain alert | Who reviews it, what action is considered, and where is the decision recorded? |
| A critical service provider becomes unavailable | Which services are affected, who coordinates the response, and what alternatives exist? |
| Customer asset records do not reconcile | Who investigates, how are affected assets identified, and what escalation follows? |
| Revenue falls substantially below forecast | What spending, funding or business decisions would management consider? |
| A group executive requests an exception to a control | Who has authority to decide, and how is challenge documented? |
| A proposed product differs from the application | Who reassesses the permissions and approves any launch decision? |
For each scenario, practise explaining:
Trigger → responsible person → decision → action → escalation → evidence.
The purpose is to identify uncertain decisions and improve the underlying arrangements before the interview.
8. Build a Focused Evidence Pack
A useful interview preparation pack should help attendees locate the evidence supporting their answers.
Depending on the applicant’s activities, it might include:
- The submitted application and subsequent responses.
- The regulatory business plan and permission analysis.
- Organisation charts and responsibility documents.
- Customer journeys and transaction flows.
- Risk assessments and key control procedures.
- Financial forecasts and supporting assumptions.
- Relevant outsourcing arrangements.
- Testing reports and remediation records.
- Implementation plans and outstanding dependencies.
- A record of material changes since submission.
Use an index identifying the document, version, owner and relevant section.
For rehearsal, ask attendees to connect important statements to evidence. “Withdrawals require dual approval”, for example, should lead to the applicable procedure and an explanation of how that control has been tested.
9. Explain Implementation Status Accurately
Management should distinguish arrangements that are:
- Designed and approved.
- Configured or implemented.
- Tested.
- Operating in practice.
- Still dependent on a future action.
These descriptions are not interchangeable.
The FCA expects final, reviewed and appropriately signed-off application documents. It also makes clear that willingness to fix deficiencies does not compensate for submitting a poor application. FCA
Where implementation remains outstanding, prepare a precise explanation of the dependency, responsible owner, completion date and verification method. Explain whether it affects the firm’s ability to provide the relevant service.
Avoid presenting a future commitment as a completed control.
10. Conduct a Mock Interview and Resolve the Findings
A useful rehearsal should challenge the application’s substance.
Ask participants to explain their responsibilities in their own words, then introduce follow-up questions and practical scenarios. Compare their answers with the submitted documents.
Record findings under clear categories:
- Knowledge or training gaps.
- Inconsistent documents.
- Unclear responsibilities.
- Missing evidence.
- Control weaknesses.
- Changes requiring disclosure or application updates.
Assign an owner to each finding and verify its resolution.
A polished answer should follow a resolved issue. Where the issue remains open, management should understand and accurately describe its status.
11. Answer Clearly and Handle Uncertainty Honestly
During the interview, a useful response structure is:
- Answer the question directly.
- Explain the relevant process or rationale.
- Identify supporting evidence.
- State any qualification or outstanding point.
If a factual detail needs checking, say so and arrange a verified follow-up. Avoid guessing figures, inventing test results or overstating personal involvement.
Where an answer differs from the application, explain whether the application contained an error, circumstances have changed, or the question requires further clarification.
After the meeting, maintain a record of requested information, commitments, owners and deadlines. Check written follow-ups against the application and the answers given.
How CRYPTOVERSE Can Support Your Preparation
CRYPTOVERSE is a specialist legal and regulatory firm for UK FCA cryptoasset authorisation support.
Our support can include reviewing the permission analysis, assessing consistency across application documents, mapping management responsibilities, preparing evidence packs and conducting mock interviews tailored to the proposed business.
The objective is to help management explain its business accurately and address substantive gaps before regulatory discussions.
Contact CRYPTOVERSE to discuss FCA crypto application interview preparation and management readiness.
FAQs
1. What should management prepare for an FCA crypto application interview?
Management should understand the applicant’s business model, requested permissions, financial resources, governance arrangements, operational risks and compliance controls. Each attendee should be able to explain their responsibilities and support important statements with relevant evidence.
2. Does every FCA crypto applicant have to attend an interview?
No. The process depends on the type of application and the FCA’s assessment. MLR registration interviews, FSMA authorisation discussions, individual assessments and pre-application meetings serve different purposes. Applicants should confirm the meeting’s purpose and attendance requirements with the FCA.
3. What questions might the FCA ask an MLRO during a crypto application interview?
An MLRO may need to explain the firm’s financial crime risks, customer due diligence, transaction monitoring, alert investigations, escalation procedures and the effectiveness of its controls. They should also understand the limitations of monitoring tools, their available resources and how they can challenge commercial decisions that create financial crime risks.
4. What documents should a company prepare for an FCA crypto application interview?
Depending on the application, useful documents may include the regulatory business plan, permission analysis, organisational charts, responsibility statements, customer transaction flows, risk assessments, compliance policies, financial forecasts, outsourcing agreements and testing records. An indexed evidence pack helps management locate supporting information quickly.
5. Does passing an FCA crypto application interview guarantee authorisation?
No. An interview is part of the wider regulatory assessment and does not guarantee authorisation. The FCA may consider the application documents, management competence, financial resources, governance, operational controls and any outstanding information or deficiencies before reaching a decision.