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In brief

The FCA’s final rules for cryptoasset financial promotions, published in June 2023, will take effect from Sunday 8 October. Those marketing in-scope cryptoassets to UK consumers, including those based overseas, will need to ensure without delay that preparations are in place for the start of the rules.

There is no doubt that the implementation period, which was shortened to four months from the six months originally proposed, has been a challenging deadline for the industry to achieve. However, in welcome news, the FCA has recognised the technological difficulties in preparing “back end” changes to meet the implementation deadline, offering a partial transition period to certain firms to enable changes to be made.

Whilst many firms already operating in the UK will be well-aware of these rules, overseas firms and new entrants to the market may still be facing a steep compliance build to comply with the new FCA rules. With the introduction of new rules on the financial promotion of cryptoassets fast approaching, we set out a summary of the rules and legal routes for promotion going forward, along with some do’s and don’ts to help firms make their final compliance preparations.

Jasmine Ginty, Trainee Solicitor, contributed to the drafting of this alert.

Click here to read the full alert.


Mark heads the Financial Services & Regulatory (FSR) practice group in London and co-leads the FinTech group. He also acts as Chair of the FSR practice for the EMEA region and sits on the Global FSR Steering Committee. Mark is ranked as a Leading Individual in Legal 500 2022 for Financial Services (Non-Contentious Regulatory) and is individually ranked in Chambers 2022 for FinTech. He is described in these publications as being "very knowledgeable" and "very approachable" with "a wonderful range of FinTech experience" and as someone who is "clear, commercial and pragmatic and understands all the issues in detail." He has authored a number of articles and contributions for leading journals and other publications, most notably the Journal of International Banking and Financial Law, the International Guide to Money Laundering Law and Practice, and A Practitioner's Guide to the Law and Regulation of Financial Crime.


Sarah Williams is an associate in the financial services practice in London. Sarah advises a broad range of clients on financial services legal and regulatory issues. Sarah's practice includes advising on the regulation of payment services and electronic money, investment firms and consumer credit providers and anti-money laundering compliance issues.


Kimberly Everitt is Baker McKenzie's knowledge lawyer for Financial Services Regulation & Enforcement, covering the EMEA region, and brings over a decade of experience to the team in both knowledge and fee-earning roles. Prior to joining Baker McKenzie, Kim held roles specializing in contentious financial services regulation knowledge, and her fee-earning roles covered non-contentious regulation in the private equity and general financial services sectors.

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