FinTech Crypto Asset Trading Platform — UK FCA Registered

FCA Cryptoasset Compliance Architecture

• FCA Cryptoasset Registration (MLRs 2017): registered as a cryptoasset exchange provider.
• FCA Financial Promotions (January 2024): crypto promotions must include risk warning ("Don't invest unless you're prepared to lose all the money you invest"), 24-hour cooling-off period for new customers, personalised risk warning based on self-assessed knowledge.

FCA Consumer Duty

"appropriate risk warnings are a cornerstone of crypto Consumer Duty compliance."

Platform

compliance prompts on every transaction, risk warning on every login for retail customers, prominent "crypto is high risk, unregulated" messaging.

AML/CTF for crypto

• Transaction Monitoring (rule-based + ML alerts), Customer Due Diligence (CDD — enhanced due diligence above £1,000 daily transaction threshold), Sanctions Screening (OFAC, OFSI, UN Consolidated List — screened on every deposit/withdrawal), and Suspicious Activity Reporting (SAR — automated SAR draft when TM alert confirmed).
• Travel Rule (Crypto Travel Rule — UK implementation June 2023): transfers above 1,000 EUR/equivalent require originator and beneficiary information (VASP-to-VASP transfers).

ComplyAdvantage API

• real-time sanctions and PEP screening.
• High-

Crypto trading order book

limit orders and market orders.

Order matching engine

Node.js with in-memory order book (BTree sorted structure — price/time priority matching).

Performance target

10,000 orders/second (peak trading during market volatility).

Redis sorted sets

real-time order book publication (bid/ask spread published via WebSocket to all connected clients within 50ms of order event).

PostgreSQL

trade history, executed orders, user balances — append-only event log (no order updates, only new events).

Reconciliation

hourly balance reconciliation (sum of all user balances from event log vs total custodied assets).

Crypto custody

hot wallet (Fireblocks API — MPC-based custody) for immediate withdrawals (up to daily limit), cold wallet (Ledger Enterprise — hardware security module) for bulk storage (95% of assets).

Withdrawal workflow

user requests withdrawal → AML screening → cooling-off period (24 hours for amounts above £5,000) → senior compliance officer approval above £50,000 → Fireblocks hot wallet withdrawal (instant) or cold wallet transfer (1 business day).

Whitelist addresses

user can only withdraw to KYC-verified addresses (reduces theft risk). 2

FA mandatory

TOTP required for all withdrawals.