GBBC Response to FCA Consultation Paper CP25/25 (Part II)

GBBC has submitted its response to the FCA’s CP25/25 (Part II), covering high-level standards, governance, operational resilience, outsourcing, and financial-crime requirements for cryptoasset firms entering the FSMA regime.

Our response supports the FCA’s direction of embedding crypto within existing financial-services standards, while highlighting the need for clear mapping guidance, proportionate calibration, and international coherence (particularly with MiCA and DORA).

Key points include:

• Clear mapping of DIB requirements to crypto activities

• Interpretive guidance for applying PRIN, COND, and SYSC to decentralised systems

• Proportionate expectations for emerging or small firms

• Strong backing for the FCA’s stance on permissionless DLT

• Crypto-specific guidance on financial-crime typologies and Travel Rule obligations

🔗 Read the Full Response

GBBC remains committed to supporting a clear, coherent, and internationally competitive UK framework for digital assets.