Britain's financial regulator has told the firms it supervises how it thinks existing anti-money-laundering and resilience rules apply when they use crypto apps that run on code instead of a middleman, and it wants comments by Nov. 18, 2026; the FCA gives no time of day for the close. The Financial Conduct Authority (FCA) opened GC26/7, a consultation on draft guidance, on Oct. 21 [1]. Nothing in it is in force; the FCA plans to publish final guidance in January 2027 [1].
What the FCA is proposing
Decentralised finance, or DeFi, is the FCA's "general term for financial services facilitated by distributed ledger technology and featuring high levels of automation, open and interoperable technology, and, in some cases, no traditional intermediary" [1]. The draft is "non-Handbook guidance," meaning it sits outside the FCA's formal rulebook, and it aims to help firms "understand how existing operational resilience and financial crime requirements may apply when they provide financial services using DeFi" (p. 1, para 1.2) [2].
It covers FCA-regulated firms that fall under three sets of obligations (p. 1, para 1.3) [2]. SYSC 15A and SYSC 6 are chapters of the FCA's systems-and-controls rules, on operational resilience and on compliance and financial crime. The MLRs are the Money Laundering Regulations, the UK law that requires firms to check customers and report suspicious activity.
Old rules, new reading
The FCA says this is not new policy. "The proposed guidance seeks to clarify existing rules rather than establish new policy" (p. 2, para 1.10) [2], and "This guidance does not create new regulatory requirements" (p. 5, para 1.11) [2]. What it adds are "observations on the current risk landscape" and "illustrative examples of measures firms may wish to consider" [1].
For a bank, broker or crypto firm that routes customers to a lending pool or trading protocol, that is the practical change: the FCA is spelling out what it expects their controls to look like when no company sits on the other side.
When things happen
The guidance arrives alongside a wider rebuild of UK crypto rules. The timeline below, taken from FCA pages, shows how the consultation fits.
Sources: FCA GC26/7, CP26/36 and cryptoassets pages, Oct. 21, 2026. Timeline: Le Coin.
The FCA asks firms to read GC26/7 with CP26/36, a second consultation published the same day [1]. That paper explains "new exclusions from cryptoasset regulation, following recent legislative changes," and its comments also close on Nov. 18 [3]. The FCA says the new regime comes into force on Oct. 25, 2027 [3], and firms with existing UK crypto business that want to carry out newly regulated activities must apply between Sept. 30, 2026 and Feb. 28, 2027 [3][4].
The objection
In Le Coin's view, guidance that "does not create new regulatory requirements" still shapes what supervisors expect, and firms that ignore it may struggle to explain why. The FCA's PDF also gives a looser target for the final text, "Q1 2027" (p. 3, para 1.12), than the web page's January [1][2].
The tell
In Le Coin's view, the tell is how much of the January final text moves from "illustrative examples" toward concrete expectations for firms that connect customers to these apps.
Sources
[1] FCA, "GC26/7: Decentralised finance guidance (DeFi)," web page, Oct. 21, 2026. https://www.fca.org.uk/publications/guidance-consultations/gc26-7-decentralised-finance-guidance (accessed Oct. 21, 2026, 1:42 p.m. ET) [2] FCA, GC26/7 guidance consultation, PDF, 24 pp. https://www.fca.org.uk/publication/guidance-consultation/gc26-7.pdf (accessed Oct. 21, 2026, 1:42 p.m. ET) [3] FCA, "CP26/36: Cryptoasset perimeter guidance," web page, Oct. 21, 2026. https://www.fca.org.uk/publications/consultation-papers/cp26-36-cryptoasset-perimeter-guidance (accessed Oct. 21, 2026, 1:42 p.m. ET) [4] FCA, cryptoassets information for firms. https://www.fca.org.uk/firms/cryptoassets-information (accessed Oct. 21, 2026, 1:42 p.m. ET)
Holding the Corner.
Not financial advice.