Webinar overview:

With the UK's crypto asset regulatory framework now largely defined, firms are increasingly turning their attention from regulatory interpretation to practical implementation. While much of the industry discussion to date has focused on the scope and requirements of the incoming regime, the next challenge is understanding what effective compliance will look like in practice and how firms can prepare their governance, prudential and safeguarding frameworks for the new environment.

This webinar will explore the key themes emerging from the FCA's policy statements and consider the practical implications for firms operating in, or planning to enter, the crypto asset sector:

Wider regulatory expectations - Governance, accountability and conduct expectations – how firms should translate familiar FCA expectations into crypto asset business models, including allocation of senior management responsibilities, board and committee oversight, governance over new products and activities, conduct risk, Consumer Duty outcomes and the evidencing of effective challenge. Discussion points will include how the FCA guidance on crypto assets should be embedded into day-to-day decision-making, control frameworks and management information.

Safeguarding and custody requirements – the practical application of CASS 16 and CASS 17, including the distinction between stablecoin backing assets and safeguarding of qualifying crypto assets, segregation of client assets, record-keeping, reconciliations, due diligence over third parties and expectations around governance of safeguarding arrangements. Discussion points will focus on the operational changes firms may need to make to systems, data flows, wallets, ledgers, reconciliations, breach management and assurance over safeguarding controls.

Prudential expectations and financial resilience – how the proposed COREPRU and, CRYPTOPRU sourcebooks (and their potential interactions with  MIFIDPRU or the FCA Approach Document) may differently affect different types of firms. Discussion points will include how firms should assess applicable prudential requirements based on their activities and comply with overall financial adequacy rules. This will include topics such as building internal capital and liquidity assessments, assessing risks from ongoing operations and demonstrating the ability to wind-down in an orderly manner. It will also include a discussion of implementation challenges around governance and data.

Drawing on industry experience and regulatory developments, the discussion will highlight areas where firms may face implementation challenges, emerging supervisory expectations, and practical considerations for boards, senior management and control functions.

Learning outcomes:

By attending this webinar, participants will:

  • Understand the key governance, regulatory and accountability expectations under the new regime.
  • Key requirements and practical application of the new safeguarding rules CASS 16 and CASS 17, including custody, record-keeping, reconciliations and client asset protection.
  • Gain insight into the FCA's prudential framework and the implications for capital, liquidity, risk management and wind-down planning.
  • Identify common implementation challenges and key areas for focus as firms prepare for the introduction of the new regime.
Arka Dey

Arka Dey

Senior Manager, BDO LLP

Arka joined BDO 5 years ago and is a Senior Manager in the Financial Services Advisory Team. He is a prudential regulatory specialist who supports fin...

Arka joined BDO 5 years ago and is a Senior Manager in the Financial Services Advisory Team. He is a prudential regulatory specialist who supports financial institutions in matters such as capital adequacy, liquidity adequacy, and risk management.

He has over ten years of experience in the financial industry and has served a wide range of clients in an advisory capacity – including large banking regulators, multinational global banks, mid-sized local banks, insurance firms, investment firms (asset managers, wealth managers, CFD traders, stockbrokers), as well as other locally regulated entities within the UK such as payment service firms, electronic money issuers, AIFMs, UCITS managers.

His areas of expertise include regulatory development in areas such as risk management, stress testing, capital and liquidity adequacy assessment, recovery planning and wind-down planning. He most recently helped several UK investment firms transition into the FCA’s investment firm prudential regime (IFPR).

Arka routinely helps entities seeking FCA authorisation implement relevant processes for financial resource adequacy such as risk assessments,  capital and liquidity adequacy assessment processes, recovery plans and wind-down plans to support an authorisation application.

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Luke Patterson

Luke Patterson

Partner, BDO

Luke is a Fellow of the Chartered Institute of Accountants of England and Wales and an affiliate member of the Chartered Institute of Internal Auditor...

Luke is a Fellow of the Chartered Institute of Accountants of England and Wales and an affiliate member of the Chartered Institute of Internal Auditors, and joined BDO in 2015. Luke has over 21 years? experience in the financial services sector performing external audit, internal audit and advisory engagements within the Payment Services, Insurance and Pensions sectors.

Luke currently manages a portfolio of internal audit and advisory clients within the Payment Services, Insurance and Pensions sectors and acts as sub lead for BDO's Financial Services Advisory Payment Services sector.

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Tiana Raviranjan

Tiana Raviranjan

Director, BDO LLP

Tiana joined BDO in 2020 and is a Director in our Financial Services Advisory team. She is a qualified Chartered Accountant (ICAEW) with over 10 years...

Tiana joined BDO in 2020 and is a Director in our Financial Services Advisory team. She is a qualified Chartered Accountant (ICAEW) with over 10 years' experience, having qualified and spent over 5 years at PwC.

At BDO, along with managing a portfolio of Internal Audit clients across Financial Services focussing within PSR/EMI firms, Tiana also assists Luke in leading BDO’s Safeguarding proposition in the UK, as well supporting BDO’s international teams. 

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Zahra Ellahi

Zahra Ellahi

Associate Director, BDO LLP

Zahra is an Associate Director in BDO’s Financial Services Advisory team and joined the firm in March 2019 to strengthen its regulatory and innovative...

Zahra is an Associate Director in BDO’s Financial Services Advisory team and joined the firm in March 2019 to strengthen its regulatory and innovative finance capabilities. She previously worked at both the Financial Ombudsman Service and the Financial Conduct Authority, where she gained extensive experience of UK regulatory expectations and supervisory approach.

During her time at the FCA, Zahra was responsible for the authorisation of firms and individuals across consumer credit, change in control, Approved Persons, the Senior Managers and Certification Regime, and later Payment Services and E-Money. She worked with a broad range of firms, including banks, lenders and fintechs, assessing business model and operational risk in the regulatory space.

Her experience is particularly relevant to firms considering cryptoasset activity, especially where propositions raise questions around FCA engagement, governance, risk and conduct considerations, regulatory perimeter analysis, and the interaction between cryptoassets, payments and e-money.

She has supported innovative firms with early-stage regulatory analysis, rules mapping, governance reviews and authorisation-related work. Her  broader experience includes section 166 work, regulatory reporting reviews, and assessments of risk management and oversight frameworks.

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Jago Corry

Jago Corry

Manager, Digital Money and Payments, Payments and Innovation, UK Finance

Jago Corry is a digital money and assets policy specialist at UK Finance, leading the organisation’s input into the developing regulatory framework fo...

Jago Corry is a digital money and assets policy specialist at UK Finance, leading the organisation’s input into the developing regulatory framework for cryptoassets and stablecoins.

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BDO

BDO

BDO is the world’s 5th largest professional services network, across 167 countries and territories, with 90,000 people working towards one goal: to pr...

BDO is the world’s 5th largest professional services network, across 167 countries and territories, with 90,000 people working towards one goal: to provide our clients with exceptional service. Our financial services team consists of over 850 specialists in the UK alone and is part of a global Financial Services practice with operations in all major financial centres. Our view of the marketplace is broad, with specialist sector teams bringing experience from across all of the industry. Our expertise covers the banking and alternative finance, payments, insurance, capital markets, private equity and asset management sectors where we work with firms of varying sizes, from new entrants to the largest and most complex financial services organisations in the world.

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Individuals who are responsible for obtaining crypto authorisation, overseeing regulatory compliance, implementing prudential/safeguarding frameworks, or providing governance oversight.

C-Suite (e.g. CEO, COO), Executive or Managing Directors, Board members, Head of Compliance, Head of Risk, Head of Internal Audit.