Crypto and Digital Assets: The Finance and Compliance Talent Gap Behind the FCA’s New Regime
The UK’s new cryptoasset regime is now set. The FCA published its final rules in mid-2026, the authorisation gateway opened on 30 September 2026, and firms that want to be authorised from day one must apply by 28 February 2027, ahead of the regime starting on 25 October 2027. Firms bringing crypto businesses into full FCA regulation are finding that the hardest problem isn’t technology. It’s finding people who understand both cryptoassets and FCA regulation. This post explains where the gaps are, what the key roles need and how to hire for them.
The Regime in Brief
| Milestone | Date |
|---|---|
| Final FCA rules published | Mid-2026 |
| Authorisation gateway opens | 30 September 2026 |
| Deadline to apply for day-one authorisation | 28 February 2027 |
| Regime comes into force | 25 October 2027 |
The regime covers operating trading platforms, dealing and arranging in qualifying cryptoassets, safeguarding cryptoassets, issuing qualifying stablecoins and arranging staking. Firms currently registered with the FCA for anti-money laundering purposes will need full authorisation for these activities, bringing the SMCR, the Consumer Duty, prudential requirements and custody rules with it. Our crypto SMF recruitment page covers the Senior Managers firms will need.
Why the Talent Pool Is So Thin
Crypto finance and compliance sit where two specialisms meet, and until recently they barely overlapped. Crypto-native professionals from exchanges, custodians and protocols understand digital asset accounting, wallet reconciliation and on-chain tracing, but many have never worked in a fully regulated firm and have no experience of FCA returns, the Consumer Duty or the SMCR. Experienced professionals from traditional financial services know the regulatory framework well but have little hands-on experience of how cryptoasset transactions are recorded, valued, safeguarded and monitored.
People with genuine experience of both are rare. With hundreds of firms building authorisation applications at the same time, they are in high demand, and the sector’s historically generous pay pushes the cost up further.
The Roles Firms Need
Compliance officer (SMF16)
Someone who can lead an authorisation application under the new rules, build a compliance framework from scratch and handle financial promotions, which have been an FCA focus for crypto since 2023. See financial promotions.
MLRO (SMF17)
Crypto carries a higher financial crime risk than most sectors. The MLRO needs blockchain analytics, Travel Rule compliance, sanctions screening across wallets and experience of the FCA’s scrutiny of crypto registrations. See hiring a crypto MLRO.
Finance leadership
Accounting for cryptoassets held for the firm, for clients and in trading books; meeting the new prudential requirements; and producing regulatory returns that are new to everyone. Where the firm safeguards client cryptoassets, finance must build controls for an asset class without the settlement infrastructure of traditional securities.
Board and executive
A CEO who can be approved as SMF1 for a regulated crypto business, and, for larger firms, independent non-executives who understand both crypto and regulated governance. See regulated CEO recruitment.
What Each Role Actually Requires
- Cryptoasset accounting: valuation, classification and the difference between own and client holdings, done in practice, not just understood in theory
- Safeguarding and custody: segregation, reconciliation of on-chain and off-chain records, key management controls and resolution planning
- Financial crime at scale: finance and compliance work far more closely here than at a conventional firm; anyone who treats AML as someone else’s problem is a poor fit
- Comfort with change: the rules are new, guidance is still arriving, and supervisory expectations will develop over the first years of the regime
Where Firms Find These People
Three profiles produce the strongest hires:
- Professionals from payments, e-money or investment firms who have taken a serious, recent interest in crypto and can show real hands-on exposure
- People who have already worked inside an FCA-registered or overseas-licensed crypto business and understand both halves of the job
- Crypto-native professionals who have built regulatory knowledge, often by working alongside compliance through an application, and can speak confidently about FCA obligations
The firms getting this right usually prioritise regulatory fluency over deep crypto-native experience. Regulatory accountability is the harder gap to close after the hire; a capable regulated professional can learn crypto mechanics faster than a crypto specialist can learn to be accountable under the SMCR.
Timing Matters
An application needs named Senior Managers, a compliance and financial crime framework, and financial projections before it goes in. Working back from the 28 February 2027 deadline, firms should already have their compliance officer and MLRO engaged. Experienced candidates usually have three-month notice periods, so a search started in early 2027 may not deliver someone in time. Fractional and interim Senior Managers with authorisation experience can bridge the gap. See the authorisation journey and fractional and interim SMF cover.
Scenario: A UK crypto exchange registered for AML purposes plans to apply for authorisation under the new regime. Its head of compliance is crypto-native but has never held an SMF, and its finance team has no regulated-firm experience. We recruit an SMF16 who led an EMI authorisation and has since worked at an overseas-licensed exchange, and a fractional MLRO with crypto and sanctions experience. The existing head of compliance becomes deputy, gaining SMCR experience. The firm submits a complete application well before the day-one deadline.
Questions to Ask Crypto Candidates
- Walk us through how you reconciled client cryptoasset holdings between the blockchain and the firm’s records. What broke, and how did you fix it?
- How did you decide whether a wallet transaction needed investigating, and what tools did you use?
- What did your firm’s FCA registration or overseas licence process involve, and what was your part in it?
- Which parts of the new UK rules will be hardest for a firm like ours, and why?
- How would you explain our safeguarding arrangements to a board with no crypto background?
- Have you held, or been assessed for, a Senior Manager role? What would your Statement of Responsibilities need to cover here?
Strong answers are specific and practical. Candidates who answer in terms of technology alone, or regulation alone, usually have only half the experience the role needs. Our guide to interviewing SMF candidates covers wider technique.
Beyond Day One
Authorisation is the start, not the end. Once the regime is live, firms face the Consumer Duty for retail customers, ongoing prudential reporting, custody audits, financial promotion approvals and regular supervisory contact. Some will also need independent non-executives and, as they grow, the additional functions that come with Enhanced status. The people hired for the application should be able to run the business afterwards, or the firm should plan the transition from fractional to full-time roles. See fractional or full-time compliance officer and the first 90 days for a new MLRO or compliance officer.
Pay and Budget
Expect to pay a premium for crypto compliance and finance hires, often well above comparable roles in traditional financial services, and expect fees for specialist searches to reflect the scarcity. Fractional arrangements can control cost before authorisation. Be realistic: candidates who tick every box are rare, not just hard to find. A well-run search identifies who can close the remaining gap fastest. See our salary guide.
Crypto and Digital Asset Recruitment
Senior Managers for the new regime. Every crypto search is overseen by Adrian Lawrence FCA
Crypto Firms
Senior Managers for authorisation.
→ Crypto asset SMF recruitment → SMF authorisation supportAuthorisation journey →
Financial Crime
Crypto MLROs and teams.
→ MLRO recruitment (SMF17) → Financial crime leadershipHiring a crypto MLRO →
Compliance
Building the framework.
→ Combined SMF16/17 → Fractional MLROFinancial promotions →
Leadership
CEO and board.
→ Regulated CEO (SMF1) → Multi-SMF team buildSanctions leads →
Every crypto search is overseen by Adrian Lawrence FCA
Frequently Asked Questions
When does the UK cryptoasset regime start?
It is expected to come into force on 25 October 2027.
When must firms apply?
The authorisation gateway opened on 30 September 2026. Firms seeking authorisation from day one must apply by 28 February 2027.
Does the SMCR apply to crypto firms?
Authorised crypto firms will be subject to the SMCR like other FCA-authorised firms, so they need approved Senior Managers.
Should we hire crypto-native or regulated-sector candidates?
Most firms do best prioritising regulatory fluency, then building crypto knowledge, because SMCR accountability is harder to learn on the job.
Can we use fractional Senior Managers for the application?
Yes, if they have relevant authorisation experience and enough time for the firm’s risk.
About the Author
Adrian Lawrence FCA is the founder of SMF Capital. He is a Chartered Accountant and Fellow of the ICAEW, holds a practising certificate in his own name, and is a former listed-company Finance Director with a BSc from Queen Mary College, University of London. He founded FD Capital in 2018 and has since built a network of five specialist recruitment practices. He oversees every SMF Capital search. View Adrian’s ICAEW profile.
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Adrian Lawrence FCA is the founder of SMF Capital and a Fellow of the Institute of Chartered Accountants in England and Wales and holds an ICAEW practising certificate in his own name. He holds a BSc from Queen Mary College, University of London, and has over 25 years of experience working with boards, investors and business owners across the UK. He founded SMF Capital to help FCA and PRA-regulated firms appoint the Senior Managers the regulators expect, with the fit and proper assessment built into every search, and personally leads every Senior Manager Function search.