Caroline Black comments in Law360 on gaps in the FCA’s new crypto regime

Sep 29 2026

Media Coverage, White Collar Crime

Caroline Black, Consultant at Gherson Solicitors, has commented in Law360 on the regulatory risks and uncertainties arising from the FCA’s incoming cryptoasset regime.

The article, “Gaps In FCA’s Crypto-Regime Leave Insider Dealing Risk”, examines potential gaps in the new framework, including the treatment of price-sensitive information, safeguarding obligations and the challenges of regulating overseas crypto businesses. The new regime is due to take effect on 25 October 2027, with applications for authorisation opening on 30 September 2026.

Caroline highlights potential regulatory risks around safeguarding obligations and the challenges facing overseas crypto businesses whose platforms are accessible to UK consumers.

“This could apply where the underlying abuse of customer assets was perpetrated by a third party, if the FCA determines that the firm’s systems and controls were inadequate”.

Read the full article in Law360: Gaps In FCA’s Crypto-Regime Leave Insider Dealing Risk

©Gherson 2026

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