UK Crypto Enforcement Update

FCA targets unregistered peer-to-peer trading

The UK’s Financial Conduct Authority (FCA) has taken a significant step in its crypto enforcement activity, carrying out its first coordinated crackdown on unregistered peer-to-peer (P2P) crypto trading across multiple sites in London.

As reported across CoinMarketCap, The Block, FinanceFeeds, Forklog, The Legal Diary and COINGEEK the FCA, working alongside HM Revenue & Customs (HMRC) and the South West Regional Organised Crime Unit, visited several locations suspected of facilitating unregistered crypto trading and issued cease-and-desist notices, with evidence gathered in support of ongoing criminal investigations.

A shift in enforcement focus

This marks the first time the FCA has specifically targeted peer-to-peer crypto trading, rather than centralised platforms.

P2P trading allows individuals to transact directly without using an exchange. However, where such activity is conducted on a commercial basis, UK anti-money laundering rules require FCA registration and operating without it is unlawful.

Importantly, the FCA has confirmed that no peer-to-peer crypto traders or platforms are currently registered in the UK, reinforcing the regulator’s position that this area presents heightened financial crime risk.

Comment from Gherson

Commenting on these developments, Thomas Cattee, Partner and Head of White Collar Crime at Gherson, said:

“This latest announcement from the FCA demonstrates a continued pro-active willingness to pursue individuals alleged to be involved in unregistered crypto-asset activity”.

He noted that “the specific activity being investigated this time is unregistered peer-to-peer (person to person) crypto trading”, describing it as “part of a wider strategy to disrupt un-registered activity” and the first time the FCA has specifically focused on this area. He added that although the UK’s full crypto regulatory regime remains in development and is expected to come into force in October 2027, “various activities involving cryptoassets still require FCA registration, including for AML purposes”. He also highlighted that the FCA has previously taken action against unregistered cryptoasset activity, including illegal crypto ATM networks and unlicensed exchanges, and emphasised that “in the latest news, the FCA have demonstrated that they are willing, in conjunction with other agencies, to go after individuals alleged to be involved in unregistered peer-to-peer crypto trading”.

Part of a broader enforcement strategy

The latest operation reflects a wider trend in the FCA’s approach to cryptoassets.

Recent enforcement actions have included:

• Prosecution of illegal crypto ATM operations;
• Arrests linked to suspected unlicensed crypto exchanges;
• Increased cooperation with other law enforcement agencies.

The focus on P2P trading suggests the FCA is now turning its attention to less visible, decentralised channels, which may present increased risks around money laundering and illicit financial flows.

What this means for businesses and individuals

While the UK’s full crypto regulatory regime is not expected to come into force until October 2027, this latest action makes one point clear:

Regulatory enforcement is already active.

Businesses and individuals operating in the crypto space should carefully assess whether their activities:

• Fall within existing AML registration requirements;
• Could be considered to be commercial cryptoasset activity;
• Expose them to enforcement risk.

The FCA’s message is clear: it will not wait for the full regulatory framework to take effect before taking action.

Key takeaway

The FCA’s crackdown on unregistered peer-to-peer crypto trading signals a broadening of enforcement beyond traditional platforms.

For market participants, this represents a shift from regulatory uncertainty to active enforcement risk, even ahead of the 2027 regime.

How Gherson can help

Gherson’s White Collar Crime and Regulatory team advises on cryptoasset compliance, enforcement risk and financial crime matters.

We can assist with:

• Assessing FCA registration requirements;
• Advising on AML and regulatory exposure;
• Supporting clients facing investigations or enforcement action;
• Preparing for the UK’s evolving crypto regulatory framework.

Read more in the publications:

• CoinMarketCap — FCA Shuts Down Unregistered P2P Crypto Trading in London
• The Block — UK FCA carries out first crackdown on illegal peer-to-peer crypto trading
• FinanceFeeds — UK FCA Targets Illegal Crypto Trading in First Multi-Site London Crackdown
• ForkLog — UK Cracks Down on Illegal P2P Cryptocurrency Trading
• The Legal Diary — Diary news plus insights, commentary and appointments from the legal world 
• COINGEEK – UK disrupts first illegal peer-to-peer ‘crypto’ trading operation

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2026