Licensing readiness

Three regimes close within ninety days of each other.

Kenya, the United Kingdom and Brazil each open a cryptoasset licensing gate in late 2026. We prepare the file — category, capital, policies, gaps — working from the gazetted instrument itself, and citing it on every figure.

See what we produce Check our sources first
—UK · FCA gateway opens 30 Sep 2026
—Brazil · transition ends 30 Oct 2026
—Kenya · licensing deadline 4 Nov 2026
4jurisdictions tracked from primary instruments
22published notes, every figure referenced
116ppof gazetted Kenyan text transcribed in full
0figures taken from secondary reporting

What most firms have wrong

Three errors we find in nearly every file we are shown. Each is checkable against the instrument in a few minutes, and each is expensive to discover late.

An MLR registration does not convert into FSMA authorisation.
The FCA has confirmed that an MLR application cannot be treated as an FSMA application and that the two are assessed independently. An existing registration gives you supervisory history, not a shortcut. Firms budgeting for a variation rather than a full authorisation are budgeting for the wrong thing.
Kenya requires nine written policies at application, not four.
Regulation 6(2)(f) of Legal Notice 134 lists nine operational policies. Several widely circulated summaries still say four. A file built to the summary is short by five documents before it is read.
Brazil's phase attribution is routinely misreported.
The two-phase filing under IN BCB 704 and the assurance obligation under IN BCB 739 are separate clocks with separate scopes, and the Anexo IV carve-out at art. 1 §1 changes who is caught. Dates from one instrument are frequently quoted against the other.

We do not publish those claims without the citation. Each is written up in full, free: MLR does not convert · the Kenyan policy count · IN BCB 704.

Check us before you pay us

Everything below is free and verifiable. If our reading of the instrument does not hold up, you will find out before any money changes hands — which is the correct order.

The notes

How a figure gets into our work

  • Read the gazetted or enacted text end to end
  • Transcribe the figure with its provision number
  • Record the source class — instrument, regulator publication, or commentary
  • Cite the provision wherever the figure appears

Firms building tooling can read that store directly through the Regulatory Anchor API.

What we produce

Start at the top and work down. Nothing below requires the step above it, but the cheaper steps exist so you can test the work before committing to the expensive ones.

Tier 0

Establish whether you are in scope — from USD 79

Kenya VASP Readiness Checklist

34 points against Legal Notice 134, each citing its operative regulation. Licence-category capital table, the CBK/CMA supervision split, and the deadline calendar. PDF.

$79 Buy

UK FCA Gateway Readiness Checklist

82 points against SI 2026/102 and RAO articles 9M–9Z11: the perimeter test, the seven regulated activities, the permanent minimum requirement by activity, the client-asset fork between the new rules and CASS 17, and the published failure modes. PDF.

$149 Buy

Brazil VASP Readiness Checklist

BCB Resolutions 519–521, the capital formula, the two authorisation regimes under IN BCB 704, and the 30 October 2026 cut-off. PDF.

$79 Buy

Tier 1

Assessed against your own entity

48-Hour Regulatory Gap Check Most start here

Fixed scope, scored on your entity rather than in general. Written report within 48 hours of the completed intake questionnaire. If it is not delivered in that window the fee is refunded in full.

$500 Buy

Readiness File

Category determination with the reasoning shown, capital and liquidity calculation, document-by-document gap list, and a remediation plan ordered by the sequence in which items must actually be fixed. Five working days.

$2,500 Buy

Tier 2

Drafted for your firm, board-ready

Kenya Nine-Policy Pack

The nine operational policies required by reg. 6(2)(f) — risk management, AML/CFT/CPF, data protection, cybersecurity and IT, complaints, market conduct, consumer protection, conflicts of interest, and business continuity. Drafted for your business rather than templated, each supplied with a board paper and a draft approval minute. Ten working days.

$9,500 Buy

UK Policy Set and SM&CR Mapping

The policy set an FCA case officer will ask to see, drafted against your activity heads, plus senior management functions, prescribed responsibilities, statements of responsibilities and the responsibilities map. Ten working days.

$9,500 Buy

Brazil Anexo IV Assurance Readiness Inventory

What assurance your institution already holds against each of the eight heads of opinion in Anexo IV of IN BCB 739, with the art. 1 §1 scope carve-out and the §2 twelve-month look-back applied, returned as a gap list scoped for an auditor engagement letter. Seven working days.

$6,500 Buy

Ongoing

So the file does not go stale between now and filing

Regulatory Monitoring — Kenya, Brazil, United Kingdom

A short written note whenever something material moves in your regime, read off the primary instrument rather than the press, with what it changes in your file and what you must now do. Nothing is sent when nothing changes. Includes free updated editions of every checklist.

$1,500 / mo Subscribe

For law firms, consultancies and vendors

Resell or build on the work

White-label licence — single jurisdiction

Reproduce, rebrand and distribute the readiness checklist and policy templates for one jurisdiction under your own name, to unlimited clients or members. Twelve months, editable source files, every updated edition during the term, attribution not required.

$6,000 / yr Licence

White-label licence — all jurisdictions

Kenya, Brazil and the United Kingdom, plus any jurisdiction added during the term. Includes the regulatory anchor feed so your own team can see what changed and when.

$18,000 / yr Licence

Regulatory Anchor API — developer access

Read access to the store behind everything we publish: capital and liquidity tables, required policy lists, fee schedules, deadlines and open items per jurisdiction — each row carrying its source class and the primary-instrument URL it was transcribed from. JSON over HTTPS, keyed, versioned, with a changed-since endpoint. 10,000 requests per month; the limit is raised on request rather than upsold.

$499 / mo Subscribe

Implementation

End-to-end preparation of the application file. Scoped after a Readiness File, so both sides know what the work actually is before either commits.

$13,000–32,000 Enquire

Fees are in US dollars and exclude any applicable tax. Payment by card in advance via Stripe; an invoice is issued automatically on payment. Files are emailed after payment.

Who this is for

A good fit

  • Exchanges, custodians, brokers and payment firms inside one of the three perimeters
  • Firms holding an MLR registration who assumed it would carry over
  • Law firms and consultancies who want the underlying work rather than a referral
  • Industry associations preparing a common position for their members
  • Investors screening a portfolio for licensing exposure

Not a fit

  • Anyone who needs a filing agent — we prepare the file, we do not file it
  • Anyone who needs legal advice or a legal opinion
  • Anyone seeking a regulatory hosting or umbrella arrangement
  • Regimes we do not cover
  • Clients we cannot identify, or who are subject to UN, UK, EU, US or Japanese sanctions

Questions we are asked

Why not just use a law firm?

Use one. You will need formal advice before you file and we do not provide it. What a law firm usually will not do at this price is transcribe the instrument, build the gap list and draft nine operational policies against your actual systems and thresholds. That is the work we do, and it makes the legal review shorter and cheaper.

What are your qualifications?

TK Global OS is operated by Kaito Tsukayama and holds no Kenyan, British or Brazilian professional qualification. Our documents organise publicly available regulatory information. They are not legal advice. That limitation is stated on every deliverable and every invoice, and liability is capped at the fee paid.

What happens if the rules change after you deliver?

A factual error in a cited rule is corrected and reissued free. Changes to the rules themselves are what the monitoring subscription is for — but you are not obliged to take it, and every checklist edition update is free to prior purchasers regardless.

How do I know a figure is right?

Every figure carries the provision it came from. Check it against the instrument. If it does not match, tell us and we will correct it publicly — that has happened, and the corrections are in the notes.

Can I see a sample before buying?

The 22 published notes are drawn from the same source work and are free. If you want a specific section of a checklist before deciding, write and ask for it.

What does the intake questionnaire ask for?

Systems, thresholds, named officers, outsourcing arrangements and governance. Policies written without those read as generic to a supervisor, which is the most common reason a policy set comes back with questions.

Contact

Trading name
TK Global OS (operated by Kaito Tsukayama)
Address
#1203, 1-43-23 Ganeko, Ginowan, Okinawa 901-2214, Japan
Email
tcb.group.888@gmail.com
Phone
+81 80-7998-2442
Hours
Mon–Fri 10:00–18:00 JST (UTC+9), reply within one business day

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