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“As it uses existing rules, it’s going to be much less like a standalone framework,” Lightstone said. “A crypto firm will be treated like any normal traditional financial institution,” adding that “it will still be hard to get FCA authorization.”
For established banks and investment firms already operating under those rules, adapting to crypto may be relatively straightforward. For newer crypto businesses, however, the cost of building governance, capital and custody systems from scratch could prove considerably more burdensome.
That challenge is particularly evident in the FCA’s proposed client asset regime, applying the Clients Asset Sourcebook (CASS) framework, which would require firms to segregate customer crypto assets from company funds under trust arrangements while introducing crypto-specific operational safeguards around private keys and reconciliations.
“The CASS requirements are very onerous,” Lightstone said. “That could encourage those newcomers to merge [with], be acquired by, a traditional firm that’s already subject to CASS and has those controls in place.”
Banking adoption
The prospect of consolidation comes as banks themselves appear more willing to enter digital assets now that regulatory uncertainty is beginning to lift.
“As of today, there is less than 20% of all the banks in Europe [that] offer today any type of crypto services, so it’s heavily underserved,” said Simon Schneider, CEO of Sygnum Europe.
