FCA Financial Crime Guide and crypto: what good controls look like

The FCA's Financial Crime Guide is a key reference for expectations around financial crime systems and controls. Here's how professionals should apply it to crypto.

Introduction

Even when you are not running a crypto platform, your clients' crypto exposure increases your firm's risk surface: scams, impersonation, dubious counterparties, and pressure to move funds quickly. The FCA's Financial Crime Guide (FCG) remains a key reference point for how the regulator thinks about systems and controls. Professional firms should not treat financial crime controls as 'only for regulated platforms'. Instead, use the FCG mindset to improve your own operational resilience: • Client education that reduces scam susceptibility • Provider due diligence that screens obvious red flags • Internal policies for urgent crypto-related requests (especially from family members)

A practical 'FCG mindset' for crypto-facing professionals

1) Expect impersonation and urgency Crypto scam patterns lean heavily on urgency: 'account compromised', 'move funds now', 'you'll lose everything'. The right control is not a clever tool — it's a firm rule: no urgent movement without a second-channel verification. 2) Treat 'recovery services' as high-risk by default A predictable scam category is the fake recovery specialist. A simple firm policy helps: • No introductions to recovery firms without strict checks • Educate clients that 'guaranteed recovery' language is a red flag • Encourage reporting to the appropriate channels if scammed 3) Build an internal escalation route If a staff member receives a crypto-related request that feels off, they should know: • who to escalate to • what to log • what to avoid promising A written playbook prevents ad hoc improvisation. 4) Document continuity to reduce criminal opportunity A surprising driver of scam losses is chaos after a death or serious illness. Families are vulnerable, information is fragmented, and scammers exploit that. A documented continuity plan reduces that window. This is where Bitzo is designed to help: a non-custodial coordination layer so that the family follows a known process rather than panic.