The Financial Conduct Authority has targeted three London premises suspected of operating illegal peer-to-peer cryptocurrency businesses, extending its enforcement campaign against unregistered crypto trading alongside HM Revenue & Customs and the Metropolitan Police Service.
The FCA announced on 17 September that cease and desist letters had been issued at all three premises during an operation carried out on 10 September, requiring traders to stop any suspected illegal crypto business. The regulator has not publicly identified the premises or the individuals involved, and the enforcement action does not itself establish criminal liability.
Peer-to-peer crypto trading involves individuals buying and selling digital assets directly with one another rather than through a conventional exchange. Where that activity is carried on by way of business in the UK, the FCA says appropriate registration is required. There are currently no FCA-registered peer-to-peer crypto businesses operating in the UK.
The regulator has linked the enforcement action directly to financial-crime concerns. Unregistered businesses can operate outside controls intended to identify suspicious customers and transactions, potentially providing a route for criminals to move or launder illicit funds. Steve Smart, the FCA’s executive director of enforcement and market oversight, said the regulator and its partners would continue to identify and disrupt illegal crypto activity.
The Metropolitan Police Service also participated in the operation. Detective Sergeant Sathish Alalasundaram highlighted the speed with which cryptoassets can move across jurisdictions and the challenge this creates for investigators, requiring law-enforcement agencies to adapt disruption and investigation methods as criminal techniques evolve.
September’s action follows the FCA’s first coordinated crackdown on illegal peer-to-peer crypto trading in April. That earlier operation, carried out with HMRC and the South West Regional Organised Crime Unit, targeted eight premises across London. Cease and desist letters were issued at each site, while evidence gathered during the inspections has supported continuing criminal investigations.
The distinction between personal crypto transactions and activity carried on as a business is significant. The FCA has clarified that individuals do not require registration simply because they buy or sell cryptoassets directly with another person. The regulatory issue arises where peer-to-peer trading is conducted commercially in the UK without the registration required for cryptoasset businesses.
The enforcement drive also comes as the UK prepares for a wider cryptoasset regulatory regime. FCA guidance published on 16 September states that UK Stablecoin Rules 2026: FCA Compliance Risks for Payment Firms under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 will come into force on 25 October 2027. Applications for authorisation are due to open from 30 September 2026, covering activities including cryptoasset trading platforms, dealing, arranging deals, safeguarding cryptoassets and certain stablecoin activities.
That changing perimeter increases the importance of distinguishing between obligations that already apply and requirements that will come into force under the new regime. Firms advising crypto businesses will need to assess whether existing activities already trigger registration and HM Treasury AML Reform Raises FCA Concerns, while also preparing clients for the broader authorisation framework due in 2027.
The latest operation also demonstrates that the FCA is prepared to use site visits, cease and desist notices and FCA, SRA, ICO and ASA Act on Credit Claims Misconduct before a matter reaches prosecution. For legal advisers working with crypto businesses, the immediate question is therefore not simply how clients should prepare for future regulation, but whether their current business model already falls within existing registration and financial-crime rules.