How to Start a Crypto OTC Business in the UK (2026 Guide)

02 October 2026

If you are researching how to start a crypto OTC business in the UK, it is important to understand that setting up a company is only one part of the process.

A crypto OTC business can involve buying and selling cryptoassets for clients, arranging transactions, facilitating trades, providing liquidity or operating other digital-asset services. Depending on exactly what your business does, where it operates and who its customers are, different UK anti-money laundering, financial promotion and financial services rules may apply.

The UK is also moving toward a new regulatory framework for cryptoassets. The Financial Conduct Authority (FCA) states that its new cryptoasset regulatory regime is expected to begin on 25 October 2027, with the application window for the new regime open from 30 September 2026 to 28 February 2027.

This makes 2026 an important time for crypto founders planning a UK business.

In this guide, we explain how to start a crypto OTC business in the UK, what a crypto OTC desk does, the potential company structure, banking considerations, FCA and AML requirements, financial promotions rules, and how Activate Global Limited can assist international founders with the UK business setup process.

Important: This article provides general business and regulatory information and is not legal, tax or financial advice. Whether a particular crypto OTC activity requires FCA registration or authorisation depends on the specific business model and activities. Businesses should obtain independent UK legal and regulatory advice before commencing regulated activities.

What Is a Crypto OTC Business?

A crypto OTC business or crypto OTC desk facilitates cryptocurrency transactions directly between counterparties rather than relying exclusively on a public exchange order book.

OTC stands for over-the-counter.

Instead of a customer placing an order on a public cryptocurrency exchange, an OTC desk may arrange a direct transaction between the buyer and seller.

For example, a client may want to purchase a large amount of Bitcoin.

Rather than placing the entire order on a public exchange, the client may approach an OTC desk that can facilitate the transaction with an appropriate counterparty or liquidity source.

A typical crypto OTC business may work with:

Bitcoin
Ether
Stablecoins
Other cryptoassets
Institutional clients
High-net-worth clients
Professional traders
Cryptocurrency businesses
Fintech companies
International businesses

The precise services offered by an OTC desk determine its regulatory and compliance requirements.

Why Start a Crypto OTC Business in the UK?

The UK has a large financial-services ecosystem, an established corporate legal framework and a developing regulatory framework for cryptoassets.

For international entrepreneurs, establishing a UK limited company can also provide a formal corporate structure for conducting international business.

However, forming a UK company does not automatically give a crypto business permission to conduct regulated cryptoasset activities.

This distinction is extremely important.

A company can be incorporated at Companies House while the activities it intends to conduct may separately require FCA registration or authorisation.

The FCA currently states that businesses providing certain cryptoasset services by way of business in the UK must register with the FCA under the Money Laundering Regulations before starting those in-scope services.

Therefore, founders should think about the project in two separate stages:

Stage 1

Establish the appropriate UK corporate structure.

Stage 2

Determine the regulatory permissions, registrations, compliance systems and operational requirements applicable to the actual crypto business.

How to Start a Crypto OTC Business in the UK

A typical setup process can involve the following steps.

Step 1: Define Your Crypto OTC Business Model

Before incorporating a company, clearly define what the business will actually do.

For example:

Will you buy and sell cryptoassets?
Will you arrange transactions between buyers and sellers?
Will you hold customer cryptoassets?
Will you hold private keys?
Will you operate a trading platform?
Will you provide custody?
Will you provide brokerage or arranging services?
Will customers be UK residents?
Will customers be institutional or retail?
Will you receive fiat currency?
Which countries will you serve?
Which cryptoassets will you support?

These questions are important because regulatory requirements can differ significantly depending on the activities.

The FCA’s current guidance explains that firms need to determine whether their activities fall within the relevant regulatory perimeter.

Step 2: Choose Your UK Company Structure

Many crypto startups use a UK private limited company as their operating entity.

A UK limited company provides a separate legal entity for conducting business, entering contracts and maintaining corporate records.

International founders can also own a UK company without necessarily being UK residents.

For entrepreneurs outside the UK, Activate Global Limited provides UK company formation for non-residents, including assistance with the incorporation process, registered office arrangements and documentation.

UK Company Formation for Non-Residents → https://activategloballimited.com/uk-company-formation-for-non-residents/

Activate Global currently offers UK company formation packages designed for non-resident entrepreneurs and states that formation can be completed remotely.

Step 3: Select the Appropriate SIC Code

When incorporating your company, you will need to describe the company’s business activities and select appropriate SIC codes.

For a crypto-related company, choosing the correct business classification should be based on the actual activities of the company.

Do not simply select a SIC code because it sounds similar to “crypto.”

Your business activity should be accurately described.

Activate Global can assist international founders with the company formation process and SIC code selection, but the founder remains responsible for ensuring that the company’s activities are accurately represented.

Step 4: Arrange a UK Registered Office

A UK company needs an appropriate registered office address.

For an international founder, a professional registered office can provide a UK corporate presence while allowing the founder to operate internationally.

Activate Global provides UK registered office services for non-resident company owners, including professional address arrangements and mail-management support.

For crypto founders, having a professional corporate structure is particularly important because banks, payment providers, professional advisers and other counterparties may conduct enhanced due diligence on the business.

Step 5: Consider Whether You Need a UK Nominee Director

A non-resident entrepreneur may also consider whether a UK resident nominee director arrangement is appropriate for their corporate structure.

This is not a substitute for regulatory authorisation and should never be used to conceal beneficial ownership.

A legitimate nominee arrangement should maintain transparency regarding the ultimate beneficial owner and comply with applicable company law, AML and KYC requirements.

Activate Global provides a UK nominee director service with documentation designed to define the nominee’s role and identify the beneficial owner.

UK Nominee Director Service → https://activategloballimited.com/nominee-director-service/

A nominee director may be relevant for certain international founders who require a UK-resident corporate structure, but the suitability of such an arrangement depends on the specific business and circumstances.

Step 6: Prepare Your Business Banking Strategy

Banking is one of the most important parts of setting up a crypto business.

Crypto businesses can face enhanced due diligence from banks and financial institutions because of the perceived financial-crime, transaction-monitoring and regulatory risks associated with digital assets.

A crypto business should therefore prepare a clear explanation of:

Business model
Source of funds
Source of wealth
Customer profile
Countries served
Expected transaction volumes
Cryptoassets handled
Counterparties
Wallet infrastructure
Compliance procedures
AML controls
Transaction monitoring
Business website
Contracts
Financial projections

Activate Global assists non-resident entrepreneurs with UK business banking applications and can help prepare the corporate and business information required for banking applications.

UK Bank Account for Non-Residents → https://activategloballimited.com/uk-bank-account-for-non-residents/

However, banking decisions remain subject to the financial institution’s own eligibility, KYC, AML and risk assessment.

Step 7: Understand the FCA Crypto Registration Requirements

This is one of the most important sections for anyone planning a crypto OTC business in the UK.

Under the current UK regime, certain crypto asset businesses carrying out in-scope services in the UK must register with the FCA under the Money Laundering Regulations before starting those services.

The FCA explains that this applies to certain crypto asset services provided by way of business where the business is carried on in the UK.

The exact requirements depend on the activity.

Examples of regulated or potentially regulated crypto activities can include activities involving:

Exchange of crypto assets
Custody of crypto assets
Arranging certain crypto asset transactions
Operating certain trading platforms
Other activities falling within the relevant regulatory perimeter

The FCA’s current perimeter guidance should be reviewed carefully because the UK’s cryptoasset regulatory framework is changing.

UK Crypto Regulation Is Changing in 2026–2027

Anyone starting a crypto business in the UK needs to understand the upcoming regulatory transition.

The FCA states that the new UK crypto asset regime is expected to begin on:

25 October 2027

The application window for the new regime opened on:

30 September 2026

and is scheduled to close on:

28 February 2027

The FCA says firms should use this period to assess which regulated activities apply to their business, determine the permissions required and prepare their applications.

The new regime is being introduced through the Financial Services and Markets Act 2000 (Crypto assets) Regulations 2026.

The FCA’s final perimeter guidance explains that from 25 October 2027, firms conducting newly regulated crypto asset activities in the UK will generally need FCA authorisation unless an exemption or relevant transitional/savings provision applies.

This is why crypto founders should not treat company incorporation as the end of the setup process.

What About FCA Registration Before 2027?

Until the new FSMA crypto asset regime starts, certain crypto businesses remain subject to the existing Money Laundering Regulations framework.

The FCA states that firms providing in-scope crypto asset services in the UK must register under the MLRs before starting those services.

The FCA also explains that firms already registered under the MLR regime will need to consider the new FSMA authorisation requirements when the new regime begins.

This means a founder planning to launch a crypto OTC business in 2026 should consider both:

Current MLR requirements

and

Future FSMA authorisation requirements.

Professional legal and regulatory advice should be obtained for the specific business model.

What Does the FCA Look For?

A crypto business applying for FCA registration or preparing for future authorisation needs to demonstrate that its business is properly structured and that appropriate compliance systems are in place.

The FCA highlights areas including:

Business model
Customer types
Products and services
Jurisdictions
Flow of funds
AML framework
Senior management
MLRO arrangements
Compliance procedures
Financial promotions
Transaction monitoring
Travel Rule procedures

The FCA expects applications to contain complete, current and business-specific information.

Appointing an MLRO

An important part of a regulated crypto business is its compliance function.

The FCA states that an applicant must appoint a Money Laundering Reporting Officer (MLRO), also known as a Nominated Officer, under the relevant MLR requirements.

The FCA expects the MLRO to have appropriate knowledge, experience and training and to have sufficient authority and independence to perform the role.

A founder should therefore plan their compliance organisation before beginning regulated operations.

AML and KYC Requirements for Crypto OTC Businesses

Anti-money laundering controls are fundamental to a crypto OTC business.

A robust compliance framework may include:

Customer Due Diligence

Verify who your customers are.

Enhanced Due Diligence

Higher-risk customers or transactions may require additional checks.

Beneficial Ownership

Understand who ultimately owns or controls corporate customers.

Sanctions Screening

Screen relevant customers and counterparties against applicable sanctions requirements.

PEP Screening

Identify politically exposed persons where required.

Transaction Monitoring

Monitor transactions for suspicious or unusual activity.

Source of Funds

Understand where transaction funds originate.

Source of Wealth

Where appropriate, understand how the customer’s wealth was generated.

Wallet Screening

Depending on the business model, wallet addresses and blockchain transaction histories may need to be assessed.

Suspicious Activity Reporting

Businesses need appropriate procedures for identifying and escalating suspicious activity.

These controls should be designed around the specific business model rather than copied from a generic template.

The UK Crypto Travel Rule

Crypto asset businesses also need to consider the UK’s Travel Rule requirements.

The FCA expects firms applying for registration to provide policies and procedures explaining how they will comply with the applicable crypto asset transfer requirements, including how originator and beneficiary information will be handled.

For an OTC business handling crypto asset transfers, this can be particularly important.

Your operational framework may therefore need to address:

Originator information
Beneficiary information
Transfer data
Counterparty VASPs
Data collection
Data transmission
Exceptions
Record keeping
Compliance escalation

Crypto Financial Promotions in the UK

Another major issue for crypto businesses is marketing.

A crypto business cannot assume that because it is incorporated outside the UK, UK financial promotion rules do not apply.

The FCA states that the financial promotions regime applies to certain crypto asset promotions communicated to UK consumers, including promotions originating outside the UK where they are capable of having an effect in the UK.

There are specific legal routes through which qualifying crypto asset promotions can be communicated to UK consumers.

These include promotions communicated by an authorised firm, promotions approved by an appropriately authorised person, certain promotions by FCA-registered crypto asset businesses relying on an applicable exemption, or promotions relying on another applicable exemption.

This means your:

Website
Google Ads
Facebook Ads
Instagram posts
LinkedIn posts
Telegram posts
Influencer campaigns
Email campaigns

may require careful review if they constitute financial promotions within the scope of the UK rules.

Can a Crypto OTC Business Advertise in the UK?

Potentially, but the business must understand the financial promotions rules before targeting UK consumers.

The FCA warns that communicating a crypto asset financial promotion outside the lawful routes can breach section 21 of the Financial Services and Markets Act 2000.

The FCA states that such a breach can constitute a criminal offence.

Therefore, a crypto startup should obtain appropriate legal/compliance advice before launching a UK consumer marketing campaign.

Crypto Business Tax and HMRC Reporting

Crypto businesses should also consider their UK tax obligations.

The UK’s crypto asset reporting framework is another important development.

HMRC states that businesses providing crypto asset services in the UK may have data collection and reporting obligations under the Crypto asset Reporting Framework (CARF).

Depending on the structure and activities of the company, founders may need professional tax advice covering:

Corporation Tax
VAT where applicable
Payroll
Accounting
Crypto asset reporting
International tax
Transfer pricing
Founder taxation
Cross-border transactions

Activate Global can help connect business owners with appropriate accounting and professional support where required.

What Documents Do You Need to Start a Crypto OTC Business?

A founder establishing a UK crypto business should generally be prepared to provide corporate and personal information such as:

Passport or government-issued identification
Proof of residential address
Director information
Shareholder information
Ultimate beneficial owner information
Business description
Expected activities
Expected turnover
Source of funds
Source of wealth
Business plan
Customer profile
Jurisdictions served
Website
Financial projections

Additional documentation may be required for FCA registration, banking and compliance assessments.

The FCA expects regulatory applications to contain complete and tailored information rather than generic documentation.

How Activate Global Limited Can Help Crypto Founders

Activate Global Limited specializes in helping international entrepreneurs establish UK businesses remotely.

For a crypto founder, our role can focus on the corporate and business infrastructure side of the setup.

1. UK Company Formation

We can assist with incorporating the UK limited company and preparing the required company information.

Our service is designed for non-resident entrepreneurs who want to establish a UK business without travelling to the UK.

Explore UK Company Formation for Non-Residents →

Activate Global currently offers dedicated UK company formation packages for non-resident entrepreneurs.

2. UK Registered Office

International founders can use a professional UK registered office address for their company.

This provides a formal UK corporate address and can help separate business correspondence from the founder’s personal residential address.

3. UK Nominee Director Service

Where appropriate, Activate Global can provide a UK resident nominee director arrangement supported by corporate documentation and beneficial ownership disclosure.

Learn About Our UK Nominee Director Service →

A nominee director does not provide FCA authorisation and should not be used to circumvent KYC, AML or regulatory requirements.

The purpose of the service is corporate structuring and, where appropriate, meeting legitimate business requirements.

4. UK Business Banking Assistance

Activate Global can also assist international founders with UK business banking applications.

Explore UK Bank Account Assistance →

For crypto businesses, banking eligibility can be more complex than for conventional businesses.

The business should provide transparent information regarding:

Crypto activities
Transaction flows
Customers
Source of funds
Compliance procedures
Expected volumes

Banking decisions remain with the relevant financial institution.

5. Business Setup Guidance

A crypto founder may need several services rather than company formation alone.

Activate Global can help coordinate the corporate setup, including:

Company formation

Registered office

Director verification

Nominee director where appropriate

Business banking assistance

Compliance support

Professional partner referrals

The exact services required depend on the business model.

A Typical Crypto OTC Business Setup With Activate Global

For an international crypto entrepreneur, the process could look like this:

Step 1 — Business Assessment

We understand your:

Country of residence
Business model
Crypto activities
Target customers
Target countries
Banking requirements

↓

Step 2 — Corporate Structure

We help establish the appropriate UK company structure.

↓

Step 3 — Registered Office

A professional UK registered office is arranged.

↓

Step 4 — Director Structure

Where appropriate, a UK nominee director arrangement can be considered.

↓

Step 5 — Banking Preparation

We help prepare the business information required for the banking application.

↓

Step 6 — Regulatory Assessment

The founder obtains appropriate legal/compliance advice regarding FCA registration or authorisation.

↓

Step 7 — Launch

The company can proceed with operations only after confirming that all required registrations, permissions and compliance arrangements are in place.

How Much Does It Cost to Start a Crypto OTC Business in the UK?

The cost depends heavily on the business model.

There is no single cost for starting a crypto OTC business.

You may have costs associated with:

UK company formation
Registered office
Director services
Business banking
Legal advice
AML compliance
MLRO
Compliance software
Blockchain analytics
Transaction monitoring
Travel Rule technology
Accounting
FCA application/registration
Financial promotion compliance
Professional insurance
Technology infrastructure
Liquidity
Operational staff

The corporate formation component can be relatively straightforward compared with the cost and complexity of operating a regulated crypto asset business.

Therefore, founders should prepare a complete business budget before launching.

How Long Does It Take to Set Up a UK Crypto Company?

The corporate incorporation process can be significantly faster than the regulatory process.

Activate Global’s standard UK company formation service is designed for remote international founders and currently advertises rapid formation timelines depending on the package and Companies House processing.

However:

Company formation ≠ regulatory approval.

An FCA registration or authorisation process can require substantially more preparation.

The FCA recommends that firms prepare their business model, AML framework, senior management information and supporting documentation carefully before submitting an application.

Can a Non-Resident Start a Crypto OTC Business in the UK?

A non-resident entrepreneur may establish a UK company, but whether the business can conduct particular crypto asset activities in the UK depends on the business model and regulatory requirements.

This is an important distinction.

You do not automatically become authorised to provide crypto asset services simply because you own a UK company.

For international founders, the correct approach is:

Corporate setup

↓

Regulatory analysis

↓

Compliance framework

↓

Required registration/authorisation

↓

Banking and operational setup

↓

Launch

Why International Crypto Founders Work With Activate Global

Launching a UK business from overseas can involve several separate providers.

One provider may handle incorporation.

Another may provide a registered office.

Another may assist with banking.

Another may provide accounting.

Another may handle compliance.

Activate Global aims to simplify the corporate setup process by bringing key UK business services together for international founders.

Our services include:

UK company formation
Registered office
Nominee director services
Business banking assistance
Annual compliance support
Business setup assistance
Professional partner referrals

Our focus is on helping international entrepreneurs establish the business infrastructure required to operate professionally in the UK.

Crypto OTC Business Checklist

Before launching your UK crypto OTC business, consider the following:

Business Model

☐ Define your OTC business model

☐ Identify your customers

☐ Identify your countries of operation

☐ Define your crypto asset activities

☐ Map your flow of funds

Company

☐ Choose company name

☐ Select appropriate SIC code

☐ Incorporate UK company

☐ Establish registered office

☐ Identify directors and shareholders

☐ Document beneficial ownership

Banking

☐ Prepare business plan

☐ Prepare source-of-funds information

☐ Prepare source-of-wealth information

☐ Prepare transaction projections

☐ Identify appropriate banking/payment providers

Compliance

☐ AML framework

☐ KYC procedures

☐ Customer risk assessment

☐ Transaction monitoring

☐ Sanctions screening

☐ PEP screening

☐ Wallet screening where appropriate

☐ Travel Rule procedures

☐ MLRO/Nominated Officer

Regulatory

☐ Determine whether MLR registration applies

☐ Review the FCA crypto asset perimeter

☐ Determine whether future FSMA authorisation applies

☐ Review financial promotions requirements

☐ Review 2026–2027 transition arrangements

☐ Obtain independent legal/compliance advice

Tax

☐ Corporation Tax assessment

☐ Accounting setup

☐ VAT assessment where applicable

☐ CARF obligations

☐ International tax review

Frequently Asked Questions

Is a crypto OTC business legal in the UK?

A crypto OTC business can operate legally in the UK, but the activities it performs may be subject to UK AML, financial promotion and financial services regulation.

Whether FCA registration or authorisation is required depends on the exact activities of the business.

Does a crypto OTC business need FCA registration?

Certain crypto asset businesses providing in-scope services in the UK must register with the FCA under the current Money Laundering Regulations framework.

The FCA’s new crypto asset regime is expected to begin on 25 October 2027, after which certain regulated crypto asset activities will require FCA authorisation.

Can a foreigner start a crypto company in the UK?

International entrepreneurs can establish UK companies, subject to applicable Companies House requirements and identity verification.

However, company ownership does not automatically provide permission to conduct regulated crypto asset activities.

Do I need a UK resident director?

A UK limited company does not generally require every director to be UK resident.

However, some international founders consider a legitimate UK nominee director arrangement for corporate, privacy or banking-related reasons.

The suitability of such an arrangement depends on the company’s circumstances.

Can Activate Global provide FCA authorisation?

Activate Global’s role is focused on UK company formation and business infrastructure.

We do not represent company incorporation as FCA authorisation.

If your crypto OTC business requires FCA registration or authorisation, you should obtain appropriate independent legal and regulatory advice and follow the FCA application process.

Can Activate Global help with a UK crypto business bank account?

Activate Global provides UK business banking assistance for non-resident entrepreneurs.

Crypto businesses may be subject to additional due diligence, and the relevant financial institution makes the final decision on account opening.

Can I start a crypto OTC business from outside the UK?

International founders can establish UK corporate structures remotely, subject to the relevant requirements.

However, whether the actual crypto activity is considered business carried on in the UK and whether FCA registration or authorisation is required must be assessed based on the specific business model.

The FCA provides guidance on when a crypto asset business is considered to be carrying on business in the UK.

Final Thoughts: Starting a Crypto OTC Business in the UK

Starting a crypto OTC business in the UK involves considerably more than registering a company.

A successful setup requires founders to understand:

Their crypto business model
UK company law
AML requirements
KYC requirements
FCA registration
Future FCA authorisation
Financial promotions
Banking
Tax
Crypto asset reporting
Travel Rule requirements
Operational compliance

The UK’s crypto regulatory environment is currently undergoing a significant transition. The FCA’s new regime is scheduled to begin on 25 October 2027, while the application window opened on 30 September 2026 and runs until 28 February 2027 for the relevant transitional arrangements.

For international entrepreneurs, the first practical step is to establish exactly what the business intends to do.

Once the business model is understood, Activate Global Limited can assist with the UK corporate infrastructure, including company formation, registered office services, appropriate nominee director arrangements and business banking assistance.

Ready to Set Up Your UK Crypto Business?

If you are planning to establish a crypto OTC desk, blockchain company, digital asset business or Web3 business in the UK, speak with Activate Global Limited about your corporate setup requirements.

Get started with UK company formation for non-residents:

https://activategloballimited.com/uk-company-formation-for-non-residents/

Need a UK nominee director?

https://activategloballimited.com/nominee-director-service/

Need UK business banking assistance?

https://activategloballimited.com/uk-bank-account-for-non-residents/

Important: Activate Global Limited provides corporate and business setup services. Company formation, a registered office or a nominee director does not itself grant FCA registration or authorisation. Crypto businesses should obtain independent legal and regulatory advice before conducting activities that may require FCA registration or authorisation.

Sources and regulatory references

The FCA’s current guidance on who needs to register, the application process, the new crypto asset regulatory regime and financial promotions should be reviewed directly because the regulatory framework is evolving.

HMRC also provides current guidance concerning the Crypto asset Reporting Framework and reporting obligations for crypto asset service providers.