Areas of focus
The work below describes the engagements Julian Hartley typically leads at the firm.
- FCA cryptoasset registration and post-registration supervision;
- NYDFS BitLicense and Wyoming SPDI applications;
- FinCEN MSB and multi-state Money Transmitter Licence rollouts;
- SEC token-classification analysis (Howey, Reves);
- MiCA CASP authorisation strategy for UK-headquartered groups;
- Cross-border structuring across Crown Dependencies;
Publications and recognition
- Contributor, Thomson Reuters Regulatory Intelligence — UK cryptoasset rules;
- Commentary in Law360 on FCA cryptoasset registration;
- Panelist, Digital Assets Week London;
- Guest lecturer, fintech regulation, on the postgraduate circuit;
Jurisdictions led by Julian Hartley
- Crypto license in United Kingdom — Financial Conduct Authority (FCA), 12–18 months (FCA).
- Crypto license in United States — FinCEN, FinCEN: weeks · MTL: 6–18 months · BitLicense: 18–24 months.
- Crypto license in Jersey — Jersey Financial Services Commission (JFSC), 12–20 weeks.
- Crypto license in Gibraltar — Gibraltar Financial Services Commission (GFSC), 16–24 weeks.
- Crypto license in Switzerland — FINMA, SRO 2–3 months · Fintech 6–9 months · Banking 12–18 months.
Services Julian Hartley leads
- Crypto License for a Crypto Exchange.
- Crypto License for a Custody Provider.
- Crypto License for a Stablecoin Issuer.
- Crypto License for a Payment Processor.
Selected client testimonials
FCA cryptoasset registration has a very high bar — Julian and his team are the reason we cleared it. Our Annex II self-assessment was rebuilt from scratch under their supervision. The financial-promotions regime work was equally rigorous.
We are one of the few firms registered with the FCA in our segment. The team’s ability to anticipate FCA RFIs before they were sent saved us months. The MLRO they introduced is a key part of our team to this day.
FCA is a long, expensive process. The firm was honest about that from the kickoff call. Eighteen months from start to authorisation, but we were authorised first time — which is rare. Worth the spend.