FCA regulatory changes impacting MoonPay's crypto services

Recent Financial Conduct Authority (FCA) updates have introduced significant changes to the financial promotion landscape, particularly for crypto firms. As of October 8, 2023, UK-based and overseas crypto firms targeting the UK market must adhere to the Financial Promotions regime. The primary goals of these regulatory measures are to:

• Protect UK consumers from inappropriate investments in crypto assets, ensuring they comprehend associated risks and
  can bear potential losses.
• Prevent consumers from feeling pressured, misled, or incentivized improperly to invest.

Compliance Obligations

To adhere to the recent FCA changes, MoonPay must do the following:

1. Clear and Transparent Marketing

Starting October 8, 2023, MoonPay must ensure all marketing materials are fair, clear, and free from misleading information. This directive aims to provide users with accurate and comprehensible information regarding the crypto services MoonPay offers.

2. General Risk Warnings

MoonPay must prominently display general risk warnings on both its website and app. This measure, effective from October 8, 2023, is intended to alert users to the inherent risks associated with cryptoassets, promoting informed decision-making.

3. Personalized Risk Warnings

Commencing January 8, 2024, MoonPay is additionally mandated to issue personalized risk warnings to all customers. This tailored approach ensures that users receive relevant information based on their specific circumstances.

4. Categorization of Crypto Investors

From January 8, 2024, MoonPay must implement a categorization system, requiring customers to classify themselves into one of three types of crypto investors.

5. Appropriateness Assessment:

As of January 8, 2024, all MoonPay customers must undergo and pass an appropriateness assessment before making any crypto purchases. This assessment ensures that users possess the knowledge and understanding to engage in crypto transactions safely.

6. 24-Hour Cooling-Off Period

For new customers onboarded on or after January 8, 2024, who successfully pass the appropriateness assessment, MoonPay must enforce a 24-hour cooling-off period before they can execute crypto transactions. It is important to note that this cooling-off period does not apply to customers who opened their MoonPay accounts before January 8, 2024.