FCA Crypto Authorisation: Building the Application Before 28 February

Applications for FCA crypto authorisation opened at 9:00am on 30 September 2026, when the relevant application period set by the FCA’s direction under regulation 52 of the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 began. That period closes at 11:59pm on 28 February 2027. Firms apply through the FCA’s Connect system, and the regime itself comes into force on 25 October 2027.

For a business already serving UK customers, the February date carries more weight than the October one. An application lodged inside the period can bring the applicant within the saving provision in regulation 53, which lets it keep operating at commencement if the application is undetermined, or refused but still open to review, and the FCA has not directed under regulation 55(3) that the run-off regime applies instead. An application lodged after it that is still undetermined at commencement leads to a run-off exemption limited to pre-existing contracts. The FCA’s 30 September press release stated the other side plainly: authorisation is not automatic, and firms that cannot show the necessary standards will not be authorised to operate in the UK market.

The opening also made the application concrete. The FCA has published a 73-page information document on the application form, a cryptoasset form for variation of permission applications, and a financial data template whose prudential tab runs the COREPRU and CRYPTOPRU calculations. A fees instrument, FCA 2026/58, came into force on the same day the window opened.

Related reading: our guide to the FCA cryptoasset regime and its authorisation gateway

The FCA crypto authorisation calendar from here

The direction, the Regulations and the FCA’s gateway pages fix these dates:

• February 2026: the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102) were made, bringing the new cryptoasset activities into FSMA regulation.
• 20 February 2026: the FCA gave its direction under regulation 52 specifying the relevant application period.
• 30 June 2026: the FCA published its final rules and guidance for the regime.
• 16 September 2026: the FCA published PS26/18, its cryptoasset perimeter guidance.
• 17 September 2026: version date of the FCA’s information document on the authorisation application form.
• 30 September 2026, 9:00am: the relevant application period opened, and the Cryptoasset Activities (Periodic and Application Fees) Instrument 2026 came into force.
• 28 February 2027, 11:59pm: the relevant application period closes.
• 31 July 2027: the FCA’s stated point after which a new registration application under the Money Laundering Regulations is unlikely to be determined before the regime starts.
• 25 October 2027: full commencement of the regime.
• End of the two years beginning with 25 October 2027: the saving and transitional chapters of Part 7 of the Regulations cease to have effect.

Regulation 52 allows the FCA to amend or replace its direction to extend the period, provided the last day still falls at least 28 days before full commencement. The FCA’s gateway page, updated on 30 September 2026, states that the period will close on 28 February 2027.

Why 28 February 2027 decides more than 25 October 2027

Under regulation 52(5), firms can still apply outside the relevant application period, and the window decides which provision a firm lands in if the FCA has not finished with its application, or has refused it, when the regime starts.

Regulation 53 is the saving provision. It applies where three conditions hold: the firm applied for a relevant cryptoasset permission during the period; the application has not been determined, or has been refused but remains open to review; and the FCA has not directed under regulation 55(3) that the run-off regime applies instead. For the activity the application covers, the firm and any overseas person in its group are treated as if Parts 3 to 6 of the Regulations had not come into force. Regulation 51 defines “open to review” to cover the period for referring a refusal to the Tribunal, a pending reference, and the appeal stages after it. The FCA describes the practical effect for existing firms as the ability to continue providing cryptoasset services, including taking on new business, while the application is assessed.

The saving provision has an override. Under regulation 55(3) and (5), the FCA may direct that a firm whose refused application is still open to review moves to the run-off regime, but only where it considers this necessary for the prevention, detection, investigation or prosecution of a criminal offence, for the protection of consumers, or to advance its objectives. Such a direction cannot take effect before full commencement, comes with a decision notice, and can be referred to the Tribunal.

Regulation 56 is the run-off exemption. Regulation 55 applies it to in-period applicants whose application has been refused and is no longer open to review, or has been withdrawn, and to any firm that applied outside the period but before commencement whose application is undetermined, refused or withdrawn. The exemption covers only what is necessary to perform pre-existing contracts. The FCA’s transitional-provision page spells out the consequence: firms in the transitional provision cannot enter into new contracts with existing UK customers or with new UK customers, and may only communicate financial promotions necessary for the performance of a pre-existing contract. They must notify the FCA and the parties to those contracts, and the FCA can vary or cancel the exemption.

A firm that does not apply at all gets neither. The gateway page says such firms must run off their UK cryptoasset business before the regime commences and will not have access to the saving or transitional provisions; carrying on afterwards risks breaching the general prohibition in section 19 of FSMA or the permission requirement in section 20.

The window closes nearly eight months before commencement. Section 55V of FSMA sets the general determination clock and requires a completed application to be determined within six months of receipt and allows up to twelve months for an incomplete one. On my reading of that general timetable, a complete application received on the last day of the window reaches its six-month limit before 25 October 2027, while an incomplete one received in February 2027 can run past it. The FCA’s own statement is narrower: it expects to determine applications submitted during the period before the regime comes into force.

What the Connect application form asks every applicant

The information document, dated 17 September 2026, reproduces the questions the form asks. Its caveats matter for planning. The FCA provides it on a best-endeavours basis, says it does not constitute guidance or legal advice, and notes that the form was still being finalised, so question wording may change in very minor ways. The applicant remains responsible for the accuracy and completeness of what it submits.

The form opens with an application builder. It asks for basic firm details, the sector, the type of activities, the individual regulated activities, the client types for each activity and any standard limitations, then generates the list of questions to complete from those answers. If the activities selected in the builder do not match the business, the questions written for the missing activity never appear in the application. The FCA’s preparation page lists rejection of an application that does not contain the minimum information it asks for as the first risk of a poor-quality application.

Three blocks follow, under the document’s own headings. “Firm details and organisation structure” covers contact details, trading arrangements, senior management functions, controllers, close links and an organisational structure chart. “Business model and strategy” carries the regulatory business plan upload, a fees section asking for projected income, financial promotion questions for firms that will approve promotions for unauthorised persons, financial forecasts and an IT self-assessment. “Governance, compliance and risk” asks for disclosure of significant events such as litigation or criminal proceedings, the firm’s financial crime prevention framework and how it will comply with the Money Laundering Regulations, a compliance monitoring plan and a complaints policy.

Two items in the first block shape the critical path. Applications for the approval of senior managers are attached inside the authorisation application, so candidates and their approval files have to be ready at submission. Controllers and close links are declared at the same point, which means a firm owned through holding companies needs its ownership chain documented before it files. The trading arrangements questions also ask whether the firm is regulated by another regulator, has other applications in progress, plans an acquisition, or is leaving a network as an appointed representative.

Firms already authorised under FSMA follow a different route. The gateway page says they need to vary their existing permissions, submitting the cryptoasset form for variation of permission applications, and the information document covers the crypto-specific questions a variation will ask. Regulation 51 defines a relevant cryptoasset permission to include a variation of an existing Part 4A permission, so an in-period variation application reaches the saving provision in the same way as a new authorisation.

Activity-specific sections, and the questions that meet overseas firms

After the common core, the form adds sections driven by the permissions selected. The information document flags a first set as relevant to the majority of cryptoasset firms: a cryptoasset records management policy, an attestation on personal account dealing in line with CRYPTO 5.8, the firm’s approach to appropriateness assessment where it has retail customers, and, for a firm based overseas applying through a UK branch, an explanation of how it will meet the FCA’s minimum standards as set out in the FCA’s Approach to International Cryptoasset Firms.

The third column records carve-outs that differ by activity. Stablecoin issuers also have a second regulator to consider: the FCA’s cost benefit analysis notes that stablecoins classified as systemic will have to comply with rules set by the Bank of England, covered in our article on the Bank of England systemic stablecoin rules.

An EU firm holding a MiCA authorisation that applies through a UK branch enters this form as an overseas applicant. The trading arrangements questions ask whether the firm is regulated by another regulator, which is where the MiCA authorisation is declared, and the UK permission is then granted or refused on the UK application. The transitional design differs as well. MiCA Article 143(3) let crypto-asset service providers that provided their services in accordance with applicable law before 30 December 2024 continue until 1 July 2026 or until authorisation was granted or refused, whichever came sooner, with Member States free to shorten that period or not to apply the transitional regime where they considered their earlier national framework less strict than MiCA; our MiCA CASP wind-down article covers how that ended. The UK version ties continuation to the date the application was lodged and, unless the FCA gives a regulation 55(3) direction, lets it run past commencement while the application is undetermined or a refusal remains open to review, for up to two years after full commencement, when the saving chapter of Part 7 ceases.

The financial data template is a prudential return in rehearsal

The financial forecasts section points to the FCA’s “Financial Data Template for Payments, E-Money and Cryptoasset Firms”. Version 1.1 added a prudential tab headed “FSMA Crypto”. The template’s guidance asks for an income statement and balance sheet with forecasts for the first three financial years and, where available, three years of historical figures including the current year. Figures are unconsolidated, in GBP and whole numbers, and must agree with the underlying accounting records. Applicants also submit their latest management accounts.

The FSMA Crypto tab is where the application starts to resemble a regulatory return. It asks for an expected authorisation date and own funds held, built up from CET1 items less deductions, plus any AT1 and T2, with references to COREPRU 3. It then derives the own funds requirement as the highest of three measures, citing COREPRU 4.1.2R:

• the permanent minimum requirement under COREPRU 4.2.1R, with an Overall Risk Assessment or ICARA attached where it exceeds GBP 150,000;
• the fixed overheads requirement, based on total annual relevant expenditure under COREPRU 4.3;
• the K-factor requirement, using crypto K-factors for stablecoins in issuance (K-SII), regulated cryptoassets safeguarded (K-RCS), client cryptoassets staked (K-CCS), client cryptoasset orders (K-CCO), cryptoasset trading flow (K-CTF), net cryptoasset position (K-NCP), cryptoasset counterparty default (K-CCD) and concentration risk (K-CON), referenced to CRYPTOPRU 4 and CRYPTOPRU 5.

Checks follow for CET1 of at least 56% of the own funds requirement, CET1 plus AT1 of at least 75%, and own funds of at least 100%, citing COREPRU 3.2.4R. The liquidity block derives a basic liquid assets requirement under COREPRU 6.2.1R from two components, one third of the fixed overheads requirement and 1.6% of guarantees to clients, and asks the firm to confirm that its core liquid assets exclude client assets and encumbered assets. A stablecoin issuer attaches a separate workbook showing its issuer liquid assets requirement and how it will meet it at authorisation and over the three-year forecast period.

One routing detail matters for MLR-registered exchanges. The template has two prudential tabs, and the one headed “PI-EMI-MLR Crypto” is for firms that will not conduct FSMA-regulated cryptoasset activities. A registered exchange applying for FSMA authorisation completes the FSMA Crypto tab, even though its current registration sits under the Money Laundering Regulations. The template also states that it does not replace the financial questions in any other form, and its capital section asks for confirmation that the firm meets every regime’s requirement without re-using the same capital resources, citing COREPRU 4.1.3G.

Application fees, and the income figure behind 2028/29 fees

Handbook Notice 144 records that the FCA Board made the Cryptoasset Activities (Periodic and Application Fees) Instrument 2026 (FCA 2026/58) on 24 September 2026. It came into force on 30 September 2026, with Part 2 of its annex coming into force on 25 October 2027, and the FCA proceeded with the application fees as consulted on:

• Category 4, GBP 2,820: arranging deals in qualifying cryptoassets, dealing in qualifying cryptoassets as agent, and qualifying cryptoasset staking.
• Category 6, GBP 11,260: dealing in qualifying cryptoassets as principal, safeguarding qualifying cryptoassets and relevant specified investment cryptoassets, and issuing a qualifying stablecoin.
• Category 7, GBP 28,150: operating a qualifying cryptoasset trading platform.

A firm applying for FSMA authorisation and MLR registration at the same time pays one application fee, the highest applicable, consistent with FEES 3.2.2G. MLR-registered cryptoasset firms pay periodic fees in fee-block G30 today; once authorised under FSMA they move into the new fee-block A.26 and do not pay in both.

Annual fees and Financial Ombudsman levies do not start until the 2028/29 fee year, and the first-year rates will be calculated from data applicants supply now. The form’s fees section asks for projected income so the FCA can calculate the fees and levies payable in the first year after authorisation. The tariff base for fee-block A.26 is annual income under FEES 4 Annex 11AR: the gross inflow of economic benefits recognised in the firm’s accounts during the reporting year in respect of the provision in the UK of the regulated activities. That base is narrower than the income statement in the financial data template, which also has lines for income from unregulated financial services and other income.

The Financial Ombudsman’s compulsory jurisdiction levy uses annual income from “relevant business” for most activities, with a flat fee for dealing as principal and for stablecoin issuance, provisionally set at GBP 0 with the intention that it will be GBP 75 for 2028/29. Relevant business means business with consumers, individuals acting for purposes wholly or mainly outside their trade, business, craft or profession.

MLR registration is a parallel track that does not convert

Cryptoasset businesses that provide in-scope services in the UK register with the FCA under the Money Laundering Regulations, and registration and authorisation run as separate tracks. The FCA’s page on registration ahead of the new regime says firms already registered will need authorisation under FSMA and that being registered does not guarantee it. Its gateway page states there will be no automatic conversion.

Registration has its own cut-offs. The FCA said it would assess registration applications submitted before the gateway opened as normal. Once the gateway opened, it encourages firms to focus on securing FSMA authorisation, and it says that a registration application made after 31 July 2027 is unlikely to be determined before the regime starts.

Existing controls still count toward the FSMA application. The FCA’s preparation page says an MLR-registered firm’s current systems and controls will help demonstrate compliance with FSMA, while pointing to market conduct, customer treatment and senior leadership as areas likely to need change. In the form, the financial crime prevention framework section asks how the firm will meet its MLR obligations, and the FCA’s June 2026 cost benefit analysis lists the MLRs and the travel rule among the existing rules that continue to apply to cryptoasset firms alongside the new regime. The international side of that obligation is covered in our FATF travel rule implementation article.

Pre-application meetings, and what they do not buy

The FCA’s pre-application support service is open to cryptoasset firms seeking MLR registration or authorisation under the new regime. Meetings are optional and free, are requested through Connect, and are run by case officers who outline the FCA’s expectations and signpost information. Where possible, the FCA tries to have the same case officer assess the application if the firm then applies. Recorded webinars, including sessions on getting authorised under the new regime and on the prudential regime for cryptoasset firms, remain available on demand.

The limits are stated on the gateway page: the FCA does not provide advice to firms, and a pre-application meeting does not guarantee a successful application. The FCA describes meetings as a chance to discuss plans or ask questions before submitting an application.

The FCA’s June 2026 cost benefit analysis gives a sense of the volume behind the gateway. It estimated a population of 325 firms, 240 small, 77 medium and 8 large, across stablecoin issuance, trading platforms and intermediaries, while stating that the estimate is subject to significant uncertainty. It put the average case officer time per firm at around 40 hours, varying significantly with the size of the firm, and assumed that larger firms would enter immediately to avoid disruption to their current business.

Rules still moving while the window is open

Applicants are building against a perimeter that is still being adjusted. PS26/18, published on 16 September 2026, finalised the perimeter guidance, and Handbook Notice 144 records that it inserted a new chapter, PERG 18, into the Perimeter Guidance Manual. HM Treasury has published the draft Financial Services and Markets Act 2000 (Cryptoassets) (Miscellaneous Amendments) Regulations 2026, introducing targeted exclusions and clarifications; legislation.gov.uk lists it as a draft instrument that has not been made.

The FCA said it would consult in October on targeted updates to its guidance covering UK qualifying stablecoins, proprietary trading and market making, certain technology providers, decentralised protocols, safeguarding arrangements involving central securities depositaries, and financial promotions. PS26/18 says the FCA aims to publish that guidance in early 2027, close to the end of the application period. The background to the perimeter is set out in our analysis of the PS26/18 perimeter guidance.

The FCA’s 16 September press release said these legal changes will not affect most crypto firms, which can use the current guidance to prepare. For a firm whose model sits in one of the six areas, my working assumption is that the application should describe the business against the perimeter as legislated today and flag where the draft amendments would change the analysis.

Sequencing the work to 28 February

The FCA’s preparation page asks firms to develop a realistic implementation plan, agreed at board level, setting out who is accountable, what needs to change, how changes will be delivered and when they will be completed. Mapped against the form, the work falls into this order:

1. Activity mapping against the PS26/18 perimeter guidance, and the choice between a new authorisation and a variation of permission.
2. Identification of senior management function holders and preparation of their approval applications for attachment.
3. The regulatory business plan and the financial data template, including the FSMA Crypto prudential tab.
4. The activity-specific policies the builder will call for and, for an overseas firm, the UK branch rationale.
5. Connect registration, and a pre-application meeting where a scoping question is still open.

The FCA encourages firms to apply as soon as possible within the period to avoid disruption to their business. Its list of what a late or poor-quality application can bring is short: rejection where the minimum information is missing, delays in assessment, refusal, and for existing cryptoasset firms, the inability to continue carrying on cryptoasset activities when the regime starts.

Frequently Asked Questions

Our UK entity applies in the window, but some UK customers are served by an overseas affiliate in the same group. Is the affiliate covered?

Regulation 53(2) extends the saving treatment to any overseas person in the same group as the applicant, for the activity the application covers. Regulation 54 then requires that overseas person to notify the FCA, as soon as reasonably practicable after 25 October 2027, that it is carrying on the activity under the saving provision, and to notify again if it stops and no longer intends to continue. If the UK applicant’s in-period application is later refused with no review left, or withdrawn, regulation 55(4) applies the run-off exemption to the overseas group member as well. Coverage follows the activity in the UK entity’s application, so an activity outside that application has no saving.

If an in-period application is refused in December 2027, which contracts count as pre-existing for the run-off?

Regulation 56(4) defines a pre-existing contract as one entered into before “the relevant day”. Where regulation 55(1) applies, the relevant day is the later of full commencement and the day the condition is met, so for a refusal that stops being open to review after 25 October 2027 it is that later day. Contracts entered while the saving provision applied fall before it. If the FCA instead gives a regulation 55(3) direction while the refusal is still open to review, the relevant day is the date the FCA specifies for that direction to take effect.

We are a FSMA-authorised investment firm adding cryptoasset custody. Is the prudential tab different for us?

In two respects. The permanent minimum requirement is entered at the highest level that applies across the firm’s current permissions and those it is applying for, so an existing permanent minimum under another sourcebook can set the figure. A non-SNI MIFIDPRU investment firm also completes the MIFIDPRU K-factor rows, such as K-AUM and K-CMH, alongside the crypto K-factors.

Can a firm lodge a thin application before 28 February and complete it later?

Section 55V allows the FCA up to twelve months to determine an incomplete application, which from a February 2027 filing runs past commencement. The FCA’s transitional-provision page says that a firm whose application is rejected because it does not include the minimum information the FCA asks for, and which does not subsequently submit a valid application, will be considered as not having applied and will need to run off its UK business before the regime goes live. A thin filing is therefore a risk to avoid, not a route to rely on.

We have an MLR registration application in flight. What happens to it now?

The FCA says it assesses registration applications submitted before the gateway opened as normal. The authorisation form’s trading arrangements section asks whether the firm has other applications for registration or authorisation in progress, which is where a pending MLR application is declared. Handbook Notice 144 says a firm applying for both FSMA authorisation and MLR registration pays one application fee, the highest applicable, and the FCA’s registration page applies that where a firm makes a case for registering after 30 September 2026 and confirms that the FCA should use its FSMA authorisation form for the registration application. Neither source states how the fee works for a registration application already lodged before the gateway opened, so that position is unconfirmed.

Our customers are experienced crypto traders. Does that shrink the Financial Ombudsman levy base?

The base still includes them if they are consumers. Handbook Notice 144 states that whether a customer is a consumer is fact-specific and that a high level of knowledge does not mean a customer is not a consumer. The FCA also declined to differentiate customers by investment knowledge, experience or familiarity with cryptoasset products when allocating the levy, provided they otherwise meet the eligibility criteria in DISP. For dealing as principal and for stablecoin issuance, the levy is a flat fee in any case.

Does the prudential tab ask for anything beyond the own funds requirement?

Yes. It has an own funds threshold requirement row, which points to COREPRU 7 and CRYPTOPRU 7, or MIFIDPRU 7, and is determined through the firm’s Overall Risk Assessment or ICARA process. The tab then checks total capital resources against the total requirement under MIFIDPRU, COREPRU and CRYPTOPRU, citing COREPRU 4.1.1R, and separately against any requirement under other regimes.

Related Articles

• FCA Cryptoasset Regime: What UK Crypto Firms Must Do Before the Authorisation Gateway Closes: the June 2026 rulebook, the new regulated activities and the move from MLR registration to FSMA authorisation.
• FCA Crypto Regime: Perimeter Guidance and the 30 September Gateway: how PS26/18 maps business models onto the new authorisation perimeter.
• BoE Systemic Stablecoin Rules: What UK Issuers and E-Money Firms Must Prepare For: the Bank of England’s regime for sterling stablecoins that become systemic.
• MiCA CASP Wind-Down: What Unauthorised Providers Must Do as the Transitional Period Ends on 1 July 2026: the EU’s end-of-transition position for crypto-asset service providers.
• FATF Travel Rule Implementation: The Enforcement Gap: where travel rule supervision of virtual asset service providers stands internationally.

Key Takeaways

• 11:59pm on 28 February 2027 is the cut-off for reaching the regulation 53 saving provision; a later application still undetermined on 25 October 2027 leads to the regulation 56 run-off for pre-existing contracts.
• The permissions picked in the Connect builder decide which questions the application contains, so the activity map comes before the form.
• The FSMA Crypto tab of the financial data template sets the own funds requirement as the highest of PMR, FOR and K-factor requirement, with CET1, AT1 and liquid-asset checks built in.
• Application fees run from GBP 2,820 (Category 4) to GBP 28,150 (Category 7, trading platforms).
• MLR-registered exchanges applying under FSMA belong on the FSMA Crypto prudential tab of the data template.
• The projected income given now is the data the FCA will use for 2028/29 fees and the Financial Ombudsman levy allocation.

Sources and References

• FCA press release, FCA opens the gateway to regulated crypto (30 September 2026): fca.org.uk
• FCA, Relevant application period direction under regulation 52 of the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (20 February 2026): FCA direction (PDF)
• FCA, Cryptoassets: how the gateway will operate (updated 30 September 2026): fca.org.uk
• FCA, The new regime for cryptoasset regulation (updated 30 September 2026): fca.org.uk
• FCA, Cryptoassets: the transitional provision: fca.org.uk
• FCA, What you need to do when preparing for the new cryptoasset regulatory regime: fca.org.uk
• FCA, Registration under the MLRs ahead of the new FSMA regime: fca.org.uk
• FCA, Pre-application support service: fca.org.uk
• FCA, Information about the authorisation application form for cryptoasset firms (version dated 17 September 2026): FCA information document (PDF)
• FCA, Financial Data Template for Payments, E-Money and Cryptoasset Firms (v1.1): FCA financial data template (XLSX)
• FCA, Cryptoasset form for variation of permission applications: FCA VoP cryptoasset form (DOCX)
• FCA, Handbook Notice 144 (September 2026), including the Cryptoasset Activities (Periodic and Application Fees) Instrument 2026 (FCA 2026/58): Handbook Notice 144 (PDF)
• FCA, PS26/18: Cryptoasset perimeter guidance (16 September 2026): fca.org.uk
• FCA press release, Crypto firms get guidance on how the new regime applies (16 September 2026): fca.org.uk
• FCA, Final rules and guidance for the cryptoasset regime (June 2026): fca.org.uk
• FCA, Cost Benefit Analysis: Cryptoasset Regime, PS26/9 to PS26/13 (June 2026): FCA CBA (PDF)
• The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102), Part 7, regulations 51 to 56: legislation.gov.uk
• SI 2026/102, as made: legislation.gov.uk
• Financial Services and Markets Act 2000, section 55V (determination of applications): legislation.gov.uk
• Draft Financial Services and Markets Act 2000 (Cryptoassets) (Miscellaneous Amendments) Regulations 2026: legislation.gov.uk
• Regulation (EU) 2023/1114 (MiCA), Article 143(3): EUR-Lex

The filing that sets the transitional track

The deliverable between now and 11:59pm on 28 February 2027 is a complete application in Connect, carrying the permissions, approvals, prudential workings and policies that the builder calls for. Inside that window, the FCA said it would consult in October 2026 on targeted updates to its cryptoasset perimeter guidance.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.