Zumo and Zeyro join forces to provide crypto firms with a compliant bridge into the evolving UK crypto market

  • The two companies have teamed up to develop a complete end-to-end solution to help crypto firms meet the rigorous requirements of the FCA’s Financial Promotions regime and enter the UK market compliantly.
  • The progressive partnership provides firms with a first step on to the regulatory bridge, with the incoming full UK regulatory regime for cryptoassets set to bring a broad range of crypto services directly into the FCA’s perimeter from October 2027.
  • The collaboration comes as Zumo’s UK Regulatory Preparedness Assessment survey reveals half of crypto firms are worried about regulatory concerns or sanctions, while 60% are still assessing how to adapt their UK operating model to the new requirements.

UK crypto-as-a-service platform Zumo has partnered with specialist regulatory and financial services firm Zeyro to provide cryptoasset businesses with a full Financial Promotions compliance package for their UK crypto marketing campaigns.

The Financial Conduct Authority’s (FCA) Financial Promotions regime is a suite of UK regulatory provisions under the Financial Services and Markets Act (FSMA) that prohibits firms from advertising financial products or services unless they adhere to rigorous standards. Any communications promoting crypto to UK consumers must follow these strict rules, regardless of where the firm is based or what technology is used.

The FCA is pursuing global crypto exchange HTX through the High Court for allegedly breaking Financial Promotions rules by unlawfully marketing cryptoasset services to UK consumers without authorisation. The case signals the end of enforcement-free marketing, showing the FCA is serious about shielding UK retail consumers from unapproved financial risk – and that its reach extends across borders to anyone marketing to UK citizens.

Zumo and Zeyro’s partnership has created a complete end-to-end solution, covering both regulatory approval and customer-facing implementation, to help crypto firms and other financial institutions enter the UK market compliantly.

Zeyro provides the regulatory sign-off that a firm’s promotions require under Section 21 of FSMA. As the approving entity, Zeyro reviews and approves any financial promotions before they go live, with communications typically reviewed within 24 hours of submission.

Zeyro’s approval isn’t a one-off exercise – it monitors approved promotions on an ongoing basis to confirm they remain accurate, compliant, and consistent with the version initially signed off. It also retains a full audit trail of submissions, approvals, feedback, and amendments for regulatory record keeping.

Through an API or an embeddable widget, Zumo then provides the complete technical infrastructure that enables firms to deliver the Financial Promotions compliance flow to their end customers, including personalised risk warnings, self-categorisation, appropriateness assessments, cooling-off periods, and confirmation of acceptance. Customer responses are captured and scored automatically against FCA standards, while real-time notifications keep clients in synch with any Financial Promotions status changes.

Commenting on the partnership, Zumo’s Founder and Chief Executive Nick Jones said:

“Compliance with the Financial Promotions regime isn’t optional – and building that compliance infrastructure from scratch is a significant undertaking. It requires significant investment in compliance expertise, legal review, technology, and ongoing maintenance.”

“We have worked with Zeyro to build a robust solution that lightens the administrative load for crypto exchanges and other firms keen to access the UK market. Firms get a plug-and-play solution to address the UK Financial Promotions journey.”

Gareth Malna, Co-Founder, Zeyro, said:

“The two companies complement each other to form a complete stack for clients seeking to enter the UK market. Our joint offering with Zumo enables them to go from a standing start to being fully operational in the UK with a fully compliant infrastructure and a marketing engine ready to go from Day One.”

Continuing on the regulatory path

The FCA’s full regulatory regime for cryptoassets takes effect in October 2027. The regulator’s authorisation gateway opens on 30th September 2026, with firms advised to submit applications by the end of February to allow the FCA enough time to process the volume of requests. Those failing to do so may face limitations on operations or be required to implement wind-down plans.

Insights from Zumo’s recent survey of crypto firms serving UK customers revealed 70% identify losing the ability to serve their UK customers as a main risk of not being ready for the new regime, while half (50%) are worried about regulatory concerns or sanctions. However, just 10% of providers consider themselves fully prepared for the new rules, while 60% are still assessing how to adapt their UK operating model to the new requirements.

Where the partnership’s Financial Promotions support helps firms to market compliantly into the UK, Zumo’s flagship Crypto Access product is extending that to their operations: a fully managed UK crypto service built to carry firms into the regulated regime.

“The industry needs to adapt quickly as it steps on shore,” says Zumo’s Nick Jones. “It’s the end of start-up style business processes and unregulated business models. What’s now needed is the institutional-grade, UK-compliant infrastructure and routes to market to accommodate the new levels of operating obligations that are coming in.”

“We’re working with partners like Zeyro to provide businesses of all types with a continued gateway to the scaling UK cryptoasset market.”

Crypto firms using the joint proposition are also able to benefit from Zeyro Risk, a product specifically designed for ongoing token due diligence that helps listing and marketing teams to identify and disclose risks during, and after, the regulatory transition.

Scottish fintech GiftRound, named one of ‘Nation’s Favourite Businesses’ for 2026

With over 1.2 million people helped and more than £12 million contributed across 172,088 group collections since inception, GiftRound is recognised nationally as one of 100 small businesses celebrated ahead of Small Business Saturday

A Scottish business that helps people collect money for group gifts, completely free of fees has been named one of the ‘Nation’s Favourite Businesses’ for 2026 by Small Business Saturday UK.

GiftRound, based in Bridge of Allan, near Stirling, Scotland, with team members based across Scotland and Cornwall, has been selected as part of the national campaign, which celebrates and champions small businesses across the UK, ahead of Small Business Saturday on 5 December.

Founded by Craig Forsythe in 2018, GiftRound makes it easy for groups to organise collections for gifts and special occasions, from leaving gifts and birthdays to teacher gifts, new babies, weddings, retirements and simply showing someone you care.

The national recognition comes as Small Business Saturday launches its 2026 campaign to showcase the ‘Nation’s Favourite Businesses’. This is a new format replacing the long-running SmallBiz100.

The businesses selected this year range from independent food and hospitality to makers, service businesses and innovative companies, reflecting the diversity of the UK’s small business community.

Craig Forsythe, Founder and CEO of GiftRound, says: “Being named one of the ‘Nation’s Favourite Businesses’ is a huge honour for GiftRound. As a small team of four, we’ve built the business quietly with plenty of determination and a genuine belief that bringing people together to show they care should be simple, joyful and free from any fees. This recognition feels like a wonderful vote of confidence in that vision, and we’re incredibly proud to represent Scotland’s thriving small business community on a national stage.”

GiftRound has recently expanded its ability to support group collections for local gift cards, working with Town & City Gift Cards across more than 90 UK towns and cities.

Michelle Ovens CBE, Director of Small Business Saturday UK, continues: “Small businesses have always been, and will continue to be, among the nation’s favourite businesses. Whether on our high streets, online or embedded in local communities, they play a vital role in the places we live and in the strength of our economy.

“This year’s Nation’s Favourite Businesses are a true representation of the UK’s most-loved small businesses. From independent, family-run cafés and local restaurants, to makers, services and traders, they showcase the incredible diversity of the UK’s small business community. We know how important small businesses are and the challenges they face, so as we kick off this year’s Small Business Saturday campaign, we’re urging the public to get behind them during the most critical trading quarter of the year.”

Dan Edelman, General Manager, UK Merchant Services at American Express, concludes: “Small businesses bring energy, innovation and character to our high streets and local economies. That’s why American Express is proud to have founded Small Business Saturday and why we continue to back small businesses to help them thrive.

“This year’s Nation’s Favourite Businesses are a brilliant showcase of the UK’s entrepreneurial spirit, and we’re delighted to be providing grant funding that will help two of these inspiring businesses invest in their next chapter of growth.”

Small Business Saturday is a grassroots, non-commercial campaign which celebrates small businesses and encourages consumers to support them, originally founded by American Express in the U.S. in 2010 (the principal supporter in the UK) aimed at celebrating and uplifting independent firms by encouraging the public to support and spend with small businesses.

The 2026 campaign will culminate on Saturday 5 December, with the campaign highlighting small businesses across the UK through social media, PR and its nationwide activity.

Small Business Saturday is the UK’s most successful small business campaign. A nationwide tour is planned for November, visiting towns and cities across the UK.

GiftRound is one of the fintechs in the FinTech Scotland community.

Scottish Fintech start-up MyPetCard launches an alternative to pet insurance

3 Scottish entrepreneurs are entering the fast-growing PetTech market with a proposition it says will reshape how owners save and pay for veterinary treatment.

MyPetCard has launched a prepaid Visa Card and online platform designed to help pet owners set aside money specifically for veterinary bills and other eligible pet-care expenses while retaining control of their unused funds.

Instead of paying non-refundable monthly insurance premiums, MyPetCard customers regularly load money onto their card. Those funds can then be used directly at veterinary practices and online pet pharmacies.

Any unused money remains the cardholder’s and can be withdrawn at any time, subject to the applicable account terms. If a pet dies, the remaining balance can be returned to the customer or retained to support the care of a future pet.

By regularly building a dedicated pet-care fund, comparing veterinary and medicine prices and retaining ownership of every unused pound, customers of MyPetCard will have a transparent way to plan for their pets financial planning from day one of joining.

Recent guidance highlighted some of the limitations owners can encounter with pet insurance. Routine and preventative treatments, age of the pet and pre-existing conditions are generally excluded, and, there is also a large increase in complaints to the Competitions Ombudsman* regarding policy limitations found in the small print. 

Consumer disputes regarding pet insurance remain a significant issue within the market. According to recent data released by the Financial Ombudsman Service, there were 2,065 new pet insurance complaints lodged during the 2025/26 period, with a 41% uphold rate for resolved cases. Although this represents a slight decrease from the complaints filed in 2024/25, the volume of successful claims continues to underscore the ongoing challenges and limitations owners face. 

MyPetCard provides a distinct alternative that is not insurance. By removing the need for a claims process or waiting for third-party approvals and eliminates the risk of rejections. Customers establish a dedicated healthcare fund for their animals, ensuring that their available money can be accessed immediately to provide greater transparency and most importantly care for their pet when they need it. 

MyPetCard is not insurance and is not positioned as a direct replacement insurance. Instead, it provides an alternative financial-planning tool for people who want greater transparency and control over how they prepare for pet-care costs.

Customers joining MyPetCard will receive:

  • A prepaid Visa card for setting aside and paying money towards veterinary care and eligible pet expenses
  • Access to the 24/7 MyPetCard Vetline for veterinary advice
  • Optional access to interest-free and low-cost financing through a partner network of more than 2,000 independent veterinary surgeries, subject to status and lending terms
  • Local veterinary price-comparison services
  • A pet-medicine price search designed to help customers find competitive prices online

MyPetCard encourages customers to save regularly, helping them gradually build a dedicated fund for routine and unexpected veterinary expenses.

John Darlington, founder of MyPetCard, said:

“I wanted to create a simpler and more transparent solution that puts control back into the hands of pet owners. Having worked with veterinary practices and animal medicines for 20 years, I became increasingly frustrated by the dilemmas owners face sometimes having to choose between the cost of treatment and the care their pet needs.

“When two in three pet owners say they could not afford unexpected surgery and millions are already delaying veterinary visits because of cost, it is clear that people need another way to prepare.

“Insurance can provide protection, but exclusions,claim rejections, excesses, claim limits and rising premiums mean it does not always meet every owner’s needs. MyPetCard gives customers another option where there are no exclusions. 

“As MyPetCard grows, we will continue developing membership benefits, price-comparison services and a supportive community for animal lovers.

“This could also have a positive impact on animal welfare. No owner wants to postpone treatment because they are worried about the cost. Building a dedicated pet-care fund—and having access to tools that help reduce costs—can provide valuable reassurance when treatment is needed.”

The UK pet-care market has expanded significantly in recent years, driven by increased pet ownership. However, the affordability of veterinary care and the complexity of insurance remain significant concerns for many households.

MyPetCard aims to address this gap by providing a transparent and flexible way for owners to plan for their pets’ future care.

The service has launched nationwide, with ambitions to expand into the United States and other international markets.

MyPetCard is now open for join up and active use across the UK at www.mypetcard.co.uk.

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Modulr becomes the only non-bank payment service provider with direct access to all three major UK payment schemes

Modulr, the payments automation platform built to scale, has become a direct participant in CHAPS, the UK’s same-day high-value payment scheme, settling directly at the Bank of England. Modulr is one of the 260+ fintechs in the FinTech Scotland community.

CHAPS is a critical part of the UK’s payments infrastructure, enabling high-value, time-critical payments. In 2025 the system settled £93.9tn across a record 53.3mn payments, an average of £371.3bn every working day, according to the Bank of England.

As demand and transaction volumes grow, settling CHAPS payments directly at the Bank of England gives Modulr greater control over its payment flows and a more efficient service for customers.

This development also means Modulr is the only non-bank payment service provider (NBPSP) with direct access to all three of the UK’s major payment schemes: Faster Payments, Bacs, and CHAPS.

Myles Stephenson, Founder & CEO, Modulr, said: “Becoming a direct participant in CHAPS is a landmark moment for Modulr; we are now the only non-bank payment service provider in the UK connected directly to all three major UK payment schemes, which uniquely positions us in the market to provide a resilient payments automation platform that scales with our customers”.

Modulr has also just been named one of the world’s top fintech companies for 2026 by CNBC and Statista, a prestigious recognition that reflects the company’s growing impact and reputation on a global scale.

Modulr’s achievement is a testament to the ambition and capability within Scotland’s fintech community.


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Why payments automation is key to operational resilience for growing businesses
News from the fintechs in our community
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Fintechs Legado and Amiqus Partner to Simplify Onboarding in UK Financial Services

Left to right are Josif Grace (Legado), Elaine Burgess (Amiqus), Erin Whyte (Amiqus) and Callum Murray (Amiqus)


A new partnership between two of Scotland’s fastest-growing fintechs, Legado and Amiqus, is set to simplify the regulated client onboarding for financial services firms, as the sector faces increasing pressure to implement digital infrastructure to meet compliance requirements. Both companies were founded in Edinburgh and first connected through the FinTech Scotland community.

“Thanks to FinTech Scotland I think I’ve known Josif since pretty much the start of Legado. I remember us sat in a coffee shop in Edinburgh talking about what we were working on and mutually confirming that we didn’t have any beef, compliance onboarding was a multi £bn problem to solve and that at some point we’d overlap. Collaboration over competition is the way to go when it comes to solving problems and growing.” Callum Murray, Founder and CEO at Amiqus

From a coffee shop conversation to a partnership

The relationship between the two companies began early, with a simple conversation between founders comparing notes on what they were building. That meeting laid the groundwork for what has now become a formal collaboration more than a decade in the making.

At FinTech Scotland, our aim is to create the conditions for founders, innovators and industry to meet, share ideas and collaborate. The connection between Legado’s Josif Grace and Amiqus’s Callum Murray is a clear example of what the ecosystem is designed to enable: an early introduction that has developed into a commercial partnership with the potential to benefit the wider UK financial services sector.

Amiqus has also made the most of the opportunities available through FinTech Scotland, participating in the Financial Regulation Innovation Lab (FRIL) innovation call on AI and compliance. Through the programme, Amiqus worked with Virgin Money to explore how AI could strengthen quality control across digital and manual onboarding. After demonstrating the scalability of its platform, Amiqus moved from pilot into live production, and secured a three-year engagement.

Solving a multi-billion-pound problem

Client onboarding and compliance remain among the most complex, time-consuming and expensive processes in regulated financial services. From identity verification and anti-money-laundering checks to the secure exchange of documents and ongoing communication, firms and their clients face friction at every stage. As Callum Murray notes, it’s a multi-billion-pound problem to solve, and one that has only grown in importance as compliance and consumer duty obligations become central to how financial institutions operate.

What the partnership delivers

The technology partnership brings together Amiqus’s reusable digital identity and Anti-Money Laundering (AML) capabilities with Legado’s regulated communications and electronic signature platform. The result is seamless, connected, compliance-driven client workflows — from verifying identity biometrics to collecting, signing and evidencing documents — in one auditable journey. As part of the collaboration, Legado’s LegadoSign product will be fully integrated into the Amiqus platform.

The partnership is designed to support a range of regulated workflows, including:

Between them, the two companies share a client base that includes Virgin Money, FNZ, Quilter, Scottish Building Society, Moneyhub, and Co-op Legal Services, with a growing presence in international markets.

A decade-long peer relationship

Reflecting on the collaboration, Callum Murray, Founder and CEO of Amiqus, said: “Josif and his team had the foresight to recognise the regulatory shift in how financial institutions meet consumer duty obligations with client communications, now seen as regulated infrastructure by boards and exec teams, central to governance and operational resilience. Our reusable identity wallet is perfectly aligned with their embedded digital signature product and with FNZ as a shared client and platform, there’s a huge amount of value we can jointly deliver to their client base, supporting seamless and embedded investor onboarding experiences.”

Josif Grace, Founder and CEO of Legado, said: “Amiqus has been a peer with us amongst scaleups based in Edinburgh and connected via FinTech Scotland for more than a decade, and they’re ahead of the curve in areas like AML. We can’t wait to begin working with Callum and his team on strategic opportunities that will benefit both companies and provide significant shared value for our clients.”

Collaboration over competition

Rather than viewing overlapping ground as a source of competition, Legado and Amiqus have chosen to combine capabilities to deliver something greater than either could alone. As Callum puts it, “collaboration over competition is the way to go when it comes to solving problems and growing”. That’s a philosophy that sits at the heart of the FinTech Scotland community, and one we’re proud to see put into practice.

For the UK financial services sector, the result is a meaningful step towards simpler, faster and more secure onboarding.

Read more news from the fintechs in our community.

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Commodities Marketplace BLK secures listing on stock market via Euronext Access Dublin

Gabriele Dadò, Chief Executive Officer of BLK

BLK Global PLC secures listing on Euronext Access Dublin, with trading set to begin at 8.00am on 31 July 2026 under the ticker code BLKX. The Glasgow-based company runs www.blkcommodities.com, a technology-driven marketplace where businesses can source, buy and sell physical raw materials and commodities.

What does BLK do?

Founded in Glasgow in 2018 by shipping and technology executives Gabriele Dadò and Aleksandra Dadò, BLK runs an online marketplace where businesses around the world can buy and sell raw materials and commodities, spanning agricultural products, chemicals, energy, construction materials, industrial goods and metals.

The platform cuts out brokers and middlemen, connecting buyers directly with producers. This means businesses pay a fairer price for goods and can manage purchases more efficiently. BLK also handles the physical shipping and delivery of goods bought through the platform, making it an end-to-end solution for commodity buyers and sellers. The company operates from its Glasgow headquarters, with additional offices in Mumbai and Dubai.

Strong growth

BLK has grown quickly in recent years. Revenues rose from £5.5 million in 2024 to £20.7 million in 2025, and the company turned a profit at the operating level in the same year. More than $15 billion worth of commodity stock is currently listed on its platform. Trading in the current financial year is said to be in line with expectations, with full year results due in October 2026.

Why list now?

BLK sees the public listing as a way to build trust and awareness with customers globally, and to position itself to raise further investment as growth opportunities arise. The company is targeting annual revenue growth of over 40% and aims to become a leading name in digital commodities trading by 2030, with around 40% of revenues expected to come from the marketplace platform itself rather than shipping.

Gabriele Dadò, Chief Executive Officer of BLK, said:

“We are excited to become a public company at a pivotal moment for BLK and for the digitalisation of global commodity trade. The Euronext Access market in Dublin provides an ideal stepping stone for BLK to execute the next phase of our growth, leveraging our standing as a public company to build our profile, grow a qualified audience of customers and partners as well as enhancing the Company’s access to public and competitive capital markets, as future growth opportunities arise. This will enable us to deliver on our mission of providing transparency and access to SMEs with direct, peer-to-peer access to producers and sellers of commodities, reducing reliance on brokers and intermediaries, streamlining the procurement process and making the whole supply chain more efficient for the benefit of local economies at both ends of the chain.”

Find out more about BLK’s listing on Euronext Access Dublin.

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Crypto firms fear being shut out of the UK market as operational readiness lags behind ambition

By Zumo

● Initial findings from Zumo’s UK Regulatory Preparedness Assessment survey show seven in ten crypto firms see losing UK market access as a key risk of the incoming regulatory regime – yet just one in ten feel fully prepared for the new rules.

● With the FCA opening its application gateway in September, 60% of firms are still assessing how to adapt their UK operating model to meet the new requirements, while 30% are finding it challenging to determine which rules apply to them and what permissions are needed.

● As nine out of ten firms prepare to submit applications, these early insights from Zumo’s live survey show a gap between ambition and firms’ readiness; collaboration will be required to close this gap, with Zumo calling on firms to feed into its assessment to help make compliance a more structured, manageable process.

Crypto firms see continued access to UK customers as the most pressing matter at stake as the country’s regulatory regime takes shape but the majority acknowledge they aren’t yet ready for it, according to new research from digital assets platform Zumo.

Early insights from the company’s landmark survey of cryptoasset service providers serving UK clients reveal 70% identify losing the ability to serve their UK customers as a main risk of not being ready for the new regime. Half (50%) have concerns about financial penalties or regulatory sanctions, with the same figure worrying about subsequent loss of revenue or market share.
Following the publication of its final rules and guidance, the Financial Conduct Authority (FCA) is preparing to open its application gateway for firm authorisations on 30 September 2026, ahead of the implementation of a comprehensive regulatory regime for cryptoassets in October 2027.

However, just 10% of providers consider themselves fully prepared for the new rules, while six in ten are still assessing how to adapt their UK operating model to meet the new requirements. Eight in ten perceive their risk of not being ready in time as moderate to high, while 60% believe their current operating model would be exposed to regulatory enforcement.

Ambition ahead of execution

Their ambition, by contrast, is in little doubt.
Nine in ten firms intend to apply for authorisation during the FCA’s application window, which will shut in February 2027, and 60% expect the regime to expand their UK business – the same figure (60%) believe the incoming regime will boost interest among their customer base in crypto as an asset class.
While awareness of the regime is universal among respondents, execution is at an early stage with half (50%) of firms still at the planning phase when it comes to their regulatory readiness initiatives.

When asked about their organisation’s single biggest challenge, three in ten said it’s determining which rules apply to them and what permissions are needed. Beneath this headline challenge lies a consistent set of operational pain points, including the cost and internal resource demands of getting ready, mapping services to UK regulated activities, and implementing compliant custody or safeguarding arrangements.

Confidence that the regime is unfolding in firms’ favour remains limited: only two in ten agree it’s developing in a way that sets firms up to operate successfully in the UK.

The call for collaboration
The early insights from Zumo’s survey show the gap between ambition and firms’ current state of readiness is now the defining feature of the market.

Few are attempting to close this gap alone. Some seven in ten have sought, or plan to seek, external support from legal and compliance advisers, industry bodies, or technology providers as they work through the challenges.
Respondents are also looking for more support from the regulator. While FCA guidance to date was rated ‘fair’ by 80% of firms – with none rating it ‘poor’ – the research has uncovered a consistent set of asks: clearer guidance on regulatory scope and applicability, more time and transitional arrangements, and better signposting of UK-compliant infrastructure and technology solutions.

The FCA’s Pre-Application Support Service (PASS) meetings for cryptoasset firms are now officially underway, which provide an opportunity to connect some of the dots. These meetings give firms an opportunity to ask questions and discuss their business plans ahead of the application window.

Commenting on the emerging survey findings, Zumo’s Founder and Chief Executive Nick Jones said:
“With the UK’s regulatory regime now set in stone, authorisation will become a game changer. Authorised market participants will have the potential to shift the status quo and unlock pent-up institutional appetite.”
“The early findings from our survey indicate a market caught between ambition and execution; firms have decided the UK is worth the effort, but must overcome a number of obstacles to be ready in time to realise the opportunity. It’s encouraging that firms are treating readiness seriously and reaching for the expertise they need – the cost of getting it wrong is cutting off access to one of the world’s most compelling markets.”

“The asks emerging from this research are practical ones – clarity on scope, realistic timelines, and visibility of the infrastructure that meets UK-specific requirements. At Zumo, we’re focused on providing the UK market solutions to help firms accommodate new levels of operating obligations. From customer onboarding to UK-routed liquidity and compliant safeguarding, we’re building the core components of a full UK-ready tech stack.”

“It’s an exciting time for the UK, but also the end of an era: of offshore provision, start-up style business processes, and unregulated business models. As the industry moves onshore, providers will need access to critical partner infrastructure that can act as a bridge to the scaling UK cryptoasset market.”

Zumo’s UK Regulatory Preparedness Assessment survey is open until Wednesday 30 September 2026, and available at here.

Why financial crime detection needs a new approach

By Swagatam Sen, Founder & CEO, ControlOne

A few years ago, I sat in a meeting with a financial crime team at a major bank. They had just finished a year-long project using machine-learning to spot suspicious activity from past data. The number of alerts was down. By the usual measures, the system was doing well. Everyone in the room agreed it was an improvement.

Then someone asked a quiet question. “Are we catching more crime?”

Nobody could answer with confidence.

That moment has stayed with me. It gets to the heart of what the industry has been doing for the last decade: improving the machinery of compliance without solving the underlying detection problem. From the outside the two things look similar. They are not the same.

The problem is not the technology. It is what we choose to look at.

Money laundering is a crime of networks. Criminal organisations do not work through single accounts acting on their own. They work through coordinated groups: accounts used to move money on behalf of criminals (often called “mules”), long chains of transfers designed to hide where the money came from, and companies that exist only on paper. Any single transaction looks harmless, but put together the pattern clearly reveals criminal activity. Every major laundering method that the Financial Action Task Force (FATF) have documented over the last twenty years shares this feature. The risk sits between accounts, not within any one of them.

Yet every generation of detection system has been built to assess one account at a time.

Rules: easy to explain, but frozen in place

The first generation of these systems relied on fixed rules. Flag any cash deposit above a set amount. Raise a flag on transfers sent to high-risk countries. Rules can be checked and traced, regulators understand them, and the teams using them can explain why every alert was raised. But by their nature they never change. Criminal networks work out where the limits are set and simply route around them. The result is a system that reliably catches the tricks of the past while raising thousands of false alarms — keeping investigators busy without catching much organised crime.

Rules were never going to solve the problem. But they set an important expectation inside these institutions: that a detection system should be explainable. That expectation matters. Any architecture that replaces them has to meet it.

The first wave of machine learning: smarter scoring, same limit

The industry’s first serious move into machine learning — software that learns patterns from data rather than following fixed rules — brought genuine improvements to how alerts were sorted and how risky each customer was judged to be. These systems are quicker to update than rules, better at handling complicated combinations of information, and far more accurate by the usual measures.

But they depend entirely on clues that people have to define in advance. You have to know what you are looking for before you can teach the system to find it. It catches someone breaking a large deposit into lots of small ones only because a person told it to look for exactly that. A new laundering method that doesn’t match a known template stays invisible. The system can only ever be as good as the clues it has been given, and no one can describe a pattern the bank has never seen before.

Mapping the network: the connections become visible, but frozen in time

The realisation that financial crime is a network problem led to serious investment in approaches that map how accounts connect to one another. Instead of looking only at what a single account does, these systems learn from the links between accounts. This is genuine progress. Connecting accounts that share the same trading partners, the same hidden owners, or the same flows of money reveals patterns that account-by-account systems simply cannot see.

But most of these systems in use today treat the network as a single frozen photograph. They learn who is connected to whom at one moment in time. They do not learn the sequence of events flowing through those connections over time.

Financial crime is not a structure. It is a process. A network of mule accounts is defined not just by how it is wired together but by the rhythm of the money moving through it: the gaps in timing, the order in which accounts are used, the coordinated pattern that appears when several accounts act together over weeks or months. A frozen snapshot captures the wiring and misses the movement.

Following events over time: the timeline arrives, but not the group

The latest approaches are powerful at reasoning about sequences of events. They can learn patterns of timing across long transaction histories, apply what they have learned across different kinds of institution, and spot unusual activity that no rule-writer ever thought to describe. In some tasks like reviewing documents, writing up case summaries, building a picture of customer behaviour, they are game-changing.

But they are almost always pointed at one account at a time. One model. One customer. One timeline.

Financial crime does not operate one customer at a time. It operates across many customers at once. A system racing through individual account histories side by side is still solving the wrong problem. Doing it efficiently, and on a huge scale, but the wrong problem all the same.

What a detection system actually needs to do

Each generation has solved a real part of the problem. Rules gave us the ability to explain decisions. The first wave of machine learning gave us the ability to adapt. Mapping the network let us see the connections. The latest models let us follow events over time. But no system in use today has combined all four of these strengths while looking at the right thing.

What is needed is a system that treats whole groups of accounts; not single accounts; as the main thing it examines. One that learns the tell-tale sequences of criminal behaviour directly from the data, without needing analysts to spell out the patterns in advance. One that works out the role each account is playing within a group, not from fixed rules but from the patterns that emerge in the data itself. And one that produces an explanation you can genuinely follow: not a risk score with a rough justification bolted on afterwards, but a clear, step-by-step record showing exactly which coordinated chain of behaviour led to the decision.

This is not a matter of fine-tuning the systems we already have. It calls for something built around the criminal network, not the individual account, from the ground up.

Where this leads

The institutions spending tens of billions every year on fighting financial crime are not failing for lack of effort or money. They are running systems designed for a different problem. The question is not whether to upgrade. Regulators and investors are already forcing that conversation. The question is whether the next generation of tools will change what we look at or simply run faster while looking at the same old thing.

Closing the detection gap means starting from the right place. That means looking at the whole ring, not just one of its members.

That is what ControlOne is building.

Why payments automation is key to operational resilience for growing businesses

By Myles Stephenson, Founder & CEO at Modulr

The world is becoming increasingly uncertain, and for businesses, this means that market and economic volatility is now the norm. Disruption can hit from many angles, and if your organisation is not resilient, the consequences can be damaging both reputationally and to your bottom line.

This is something that Scottish businesses deeply understand and is reflected in their current outlook. In Scotland, for example, recent MFMac survey data shows that 25% of firms say their most recent financial year performed worse than expected (up from 16% a year earlier), while 47% now identify a weak economy as their primary concern.

But business leaders must move beyond merely admiring the problem and take steps to protect and improve their business resilience to weather these fast-evolving conditions.  

In the industries we operate in, including payroll, lending, and travel, we are seeing one thing very clearly: businesses that focus on their payments infrastructure as a driver for growth rather than a simple function are significantly strengthening their position and competitiveness.

And within this context, operational resilience is an essential element of the systems that automate money movement.

Resilience in the core payments that drive your business

Consider payroll, a function that exists in every organisation. When it goes wrong, the effect on employee productivity and engagement is considerable. Research indicates that 25% of UK employees have been hit by payroll errors, and 46% of those affected have seen it happen more than once. In more than half of cases, the problem took over a week to fix. This results in time lost as staff resolve these issues and erodes employee sentiment in an already unsettled climate, which in turn feeds into staff churn.

Businesses that have not automated payroll encounter inefficiency at every step. Manual file exports, reconciliations, and disconnected workflows introduce failure points across the process. Bringing payroll and payments together into one automated flow strips out those handoffs, cuts errors, and creates an operating model that can absorb higher volumes without adding overhead.

Real-time payments integration provides the speed, control, and transparency needed to keep up as volumes rise. Future-proofing payroll means designing systems that take change in their stride rather than buckling under it. The organisations that manage this reliably, and at scale, convert payroll from an operational liability into a foundation for lasting growth.

Speed as the new competitive edge in lending

Lending is another market where we’re seeing firms differentiate themselves through automation. Here, reliability alongside speed and accuracy in collections is key. Streamlined, automated payments strengthen operational stability by accommodating irregular or partial repayments, enabling quick schedule changes, and delivering dependable processing.

Lenders are handling high volumes of collections, reconciliations, and reporting at once, often spanning multiple products and borrower segments. In an industry where margins are thinner and borrowers more sensitive, a single payment error can create compliance risk, damage borrower relationships, and open up operational exposure at the very moment a lender can least afford it.

Automated, real-time payment infrastructure takes much of that vulnerability away. Collections are validated automatically, and reconciliation happens in real time instead of at the end of a manual process.

Building resilience in an unpredictable travel market

One of our other key sectors, travel, must also deal with its own pressures, sharpened by the cross-border nature of travel payments. Additionally, disruption has been growing in this sector for some time with no sign of easing, which makes operational resilience more critical than ever.

Earlier this year, we saw geopolitical tensions cause mass flight cancellations and disruption. More recently, the World Cup has put strain on the travel industry with last-minute travel plans being made as the tournament progresses. This presents complex challenges for travel firms.

The consumer-facing side tends to grab attention, but supplier-side problems are frequently far more intricate and demand tighter cash flow management.

Travel companies are settling payments with airlines, hotels, ground transport providers, and a range of other suppliers. When disruption and uncertainty take hold, two operational risks intensify: time swallowed up by manual processes and running short of funds at a key moment.

Many operators are still tied to manual processes and legacy infrastructure that generate errors and slow processing times, precisely when speed and precision matter most. Late or incorrect supplier payments can put partnerships under strain, activate penalty clauses, and set off a second round of operational problems at the worst possible time. The effect only grows at scale, as larger volumes across multiple currencies create further complications. With automation, payments are triggered and processed without manual involvement, supplier settlements stay on schedule whatever the level of disruption, cash flow and reconciliations are tracked in real time, and the errors that pile up in manual environments fall away.

Payment infrastructure is the foundation of operational resilience

This is a pattern that shows up time and again across payroll, lending, and travel. External pressure builds, and the businesses that manage this well are those with automated, real-time payment infrastructure beneath them.

In a world where disruption is becoming a regular feature, payment infrastructure sits at the heart of how businesses protect themselves, serve their customers, and stay competitive. The organisations that see this now will be in a far stronger position than those that wait for the next shock to discover that payment infrastructure has become much more than an operational function.

Rethinking cross‑border payments: Market Town’s Bitcoin approach from Edinburgh

Written by Henry Murray-Smith, Market Town 

“Imagine a contract where every January first, forever, I will give you one dollar. You can sell and transfer this contract. You want to sell this contract to Charlie. How much does he pay?” 

This question is really asking “why is a dollar today worth more than a dollar tomorrow?” and is as fundamental to finance as a writer of the English language starting on the left hand side of the page. Charlie buys the contract for about eight dollars. 

In 2021, five years into an informal financial education, I stood in the kitchenette of a data centre waiting for tea to brew, closing a wealth management textbook from the CISI (the Chartered Institute for Securities and Investment). Concluding my first reading I was more certain finance was, at its most favourable angle, a hot mess. And for all the detail and breadth of my education, I still had no idea what money was. 

Some years later, the best definition I can muster is that money is part of human nature. It’s a phenomenon that appears with any collection of people, expressed through technology. My favourite example is cigarettes in prison, because they’re so perfectly divisible and scarce. They also have a practical purpose: you *can* save them to trade another day, or smoke one in a moment of reflection. But step outside prison and cigarettes are no longer tender. A shopkeeper will no sooner trade cigarettes for groceries than they would accept a nugget of gold. 

When investigating money, the inevitable subject of Bitcoin appeared. My cynicism only began to erode reading Fidelity’s ‘Bitcoin First Revisited’ which explains why Bitcoin, not the thousands of other ‘web3 projects’ satisfies the properties of money to a greater degree than fiat currencies and gold. I still despised its energy consumption, because I hadn’t connected the dots that, if electricity is almost all of your running costs, finding stranded and renewable energy would be incentivised. 

I also hadn’t considered the energy cost of the current system: millions of offices, bank branches, and autoteller machines serviced by vehicles – that system full of failure points, gatekeepers and opaque fees. So what backs Bitcoin? Even if fiat currency isn’t backed by gold (anymore) it’s backed by a government’s ability to raise taxes and sell bonds. Well, it takes a lot of energy to mine one Bitcoin, almost a hundred thousand US dollars of electricity. It can’t be created without significant cost. Saying it’s backed by energy doesn’t exactly stir the soul, but it is, and the market values that captured energy, or that Bitcoin, very highly. 

So why wasn’t there a browser for the Bitcoin network, I wondered? Why didn’t some clever developer build a portal like so many thousands of startups during the early days of the internet, which had Mosaic and Netscape? The sad truth is that many of the innovation dollars went to adjacent crypto projects pretending to be superior to Bitcoin, optimised for different things, and now they’re all fading. Only Bitcoin persists, everything else dies and, yet, few use it as currency. 

Today, half a billion people own Bitcoin, most indirectly, and it’s one per cent of global money supply. Numbers like these inspire us to build the future of payments, banking and financial services. 

After eighteen months of product development, our mobile app is being designed in California by Alexander Lambert, who led the design, often from day one, of Friendster.com, car sharing platform Getaround.com, and Airkit.com (acquired by Salesforce).  

To explore our roadmap beyond global payments, say hello@market.town 

Learn more about Edinburgh fintech Market Town and its Bitcoin‑powered cross‑border payments platform.