Launching
Get FCA authorised by someone who’s done it from the inside.
We prepare the Part 4A application, build the framework the FCA expects to see, and can provide SMF 16/17 cover from day one.
- Typical timeline
- Nine to twelve months — quicker for simpler firms and variations of permission, longer for complex ones
- Who it’s for
- Spin-outs and new managers, firms leaving an Appointed Representative arrangement, and cryptoasset firms moving from MLR registration to full authorisation
- How we engage
- A fixed-scope project, or an all-in retainer that carries on after authorisation
What you get
Regulatory business plan
The permissions you need, and a plan the FCA can follow from strategy to controls.
Senior managers and SMCR
SMF applications, responsibilities map and statements of responsibilities.
Compliance manual and policies
Written for your business model, not a template with the name changed.
Financial crime framework
AML, sanctions and market abuse arrangements proportionate to your risk.
Prudential position
Own funds, liquidity and ICARA where MiFIDPRU applies.
Through to go-live
We answer the FCA’s questions with you and stay on to run the function if you want us to.
How it works
Step 1
Scope
Permissions, structure and whether direct authorisation or an Appointed Representative arrangement fits first.
Step 2
Build
We draft the application pack and the framework behind it, so it is complete when it goes in.
Step 3
Submit and respond
Several rounds of FCA questions are normal. We handle them with you until the application is complete.
Step 4
Authorised
Conditions met, permissions granted — and a framework that is already running.
Also part of a launch
Authorisation is one workstream. We can run the others alongside it.
- Entity structuring, host and domicile decisions
- Prime broker selection and onboarding
- Banking and counterparty onboarding
- Legal documentation — IMA, side letters and NDAs — before the first investor signs
- SMA launches for your first institutional mandate
- Operational due diligence readiness from day one
Cryptoasset firms
The FCA’s application window for the new cryptoasset regime runs from 30 September 2026 to 28 February 2027, ahead of the regime starting on 25 October 2027. Timings for decisions under a brand-new regime are hard to predict, so preparation matters more than usual.
James supported the launch and ongoing advisory of crypto market making businesses at Citadel Securities and IMC across the UK, EU and Singapore, was an early member of the FIA EPTA Digital Assets working group, and contributed to HM Treasury and ESMA MiCA consultations through industry groups. He brings institutional, traditional-finance standards to a crypto application: governance, market abuse controls, financial crime and prudential planning.
Questions firms ask
How long does FCA authorisation take?
The FCA must decide a complete application within six months of receiving it, and any application within twelve months. In practice most firms should plan for nine to twelve months. Simpler firms can be at the lower end or quicker; more complex firms sit at the top end, depending on FCA review time. A variation of permission for an existing firm is usually quicker. The cryptoasset regime is new, so timings there are harder to predict.
Should we start as an Appointed Representative?
Often, yes. An Appointed Representative operates under a fully authorised principal, so a firm can be trading in weeks rather than waiting for its own permissions. The principal controls your permissions, charges a hosting fee and can end the arrangement, so most firms plan a move to direct authorisation. An Appointed Representative cannot itself act as the AIFM of a fund — that function needs direct authorisation.
Do we need CPMI permissions?
A CPMI firm is an AIFM (or UCITS manager) that also has permission for MiFID services such as discretionary portfolio management or investment advice. You need it if you manage a fund and also run mandates, such as SMAs, for third-party clients. A firm managing only its own funds does not.
Can one person hold SMF 16 and SMF 17?
In hedge funds and trading firms, almost always yes: SMF 16 (compliance oversight) and SMF 17 (MLRO) are usually held by the same person. That person can also hold another role, such as COO, for a period — but not indefinitely. As the firm grows, the FCA and investors expect a dedicated compliance lead, and combined roles are often flagged at operational due diligence.
Planning an application? Talk it through first.
A 30-minute call to map permissions, structure and timing. No obligation.