RISK • THE REAL DEAL
Partnerships with global risk advisory leaders [like Aon] are a foundational element in reinforcing BCB Group’s risk strategy.
The latter approach can create momentum and growth in the short term. However, Sullivan’s experience shows that this will only get you so far: eventually, there is a painful and disruptive catch-up process. Why? Because firms that don't embed risk management first often reach a stage where their rapid growth will make them vulnerable to legacy weaknesses − and at this point, a costly and disruptive remediation process must be initiated to fix these problems. As Sullivan puts it: “In payments, trust is built long before a transaction takes place.” “Risk has to be considered
As crypto payments enter an institutional phase, regulation, safeguarding and operational resilience, not speed alone, are becoming decisive in earning long-term trust. Crypto payments at a crossroads
faster withdrawals if a provider becomes insolvent. This new framework will include more rigorous reporting, fund segregation and independent safeguarding audits. BCB Group has already started implementing these measures to ensure its clients will benefit from enhanced protection under all market conditions. MiCA harmonises the regulatory landscape across the EU to support the growth of the sector, raise standards and provide greater protection for consumers and institutions. Many CASPs find the depth and scale of MiCA daunting, as there are six rigorous steps firms must address in order to meet its requirements. These include stricter rules for some stablecoins, a cybersecurity audit, stronger IT security and operational resilience, new Travel Rules for anti- money laundering, stricter governance,
This underpins the philosophy and design of BLINC − in which risk management and operational resilience are embedded into the foundational infrastructure to support high institutional payment flows, even during market volatility. With its rigorous onboarding process and strict fund protections, BLINC enables its clients to move unlimited funds efficiently and securely without the time constraints, rigidity and high costs of the traditional payments system. THE PROMISE OF CUSTOMER SAFEGUARDING Customer safeguarding is now an important differentiator for CASPs. This means ensuring client funds are protected during extreme volatility, not just under normal operating conditions. To achieve this, CASPs must segregate client assets, define their governance and oversight structures, and understand how funds will be treated during a severe event such as insolvency. These requirements
across every layer of the system − operationally, financially and legally − not treated as an afterthought,” he adds. Institutional clients shouldn't
CRYPTO payments used to be viewed as experimental and far removed from the mainstream. That perception has changed dramatically in recent years as retail and institutional demand for digital assets has risen at an unprecedented pace. 2025 was a groundbreaking year for the institutionalisation of this sector, with more financial firms − from remittance providers to hedge funds − adopting digital assets and integrating them into their core payment, treasury and settlement flows. This shift − which has been accelerated by the surging demand for faster, flexible cross-border payments − has not gone unnoticed by the regulators either. For example, the transitional measures for the Markets in Crypto Assets Regulation (MiCA) are well underway, while the UK’s Financial Conduct Authority (FCA) has announced plans for its
own regime in an attempt to boost the competitiveness of the UK market which they have now announced will be in force in 2027. Looking ahead to 2026, building institutional trust will rely on much more than speed and capabilities. As financial institutions demand robust risk management, “enhancing resilience and ensuring rigorous safeguardingofclients’ money and assetswill be the real deal”, says James Sullivan, Chief Risk and Compliance Officer at BCB Group. As regulators in the UK and Europe place more emphasis on these two core metrics, CASPs have two choices. They can embed resilience and safeguarding into their foundations
rapidly evolved. Years ago, when volumes were much lower and transactions were smaller, institutions had relatively limited exposure to digital assets. Today, crypto payments are operated at scale across multiple jurisdictions, often through a complex network of banking partners, custodians and counterparties. This exposes digital assets to much greater operational, counterparty and systemic risks than before. RISK IS NO LONGER ABSTRACT For institutional clients, this shift fundamentally changes how crypto payment providers are assessed. Speed and functionality, while obviously desirable, can no longer be differentiators on their own. Instead, effective governance, strong safeguarding, and operational resilience have become the new baseline requirements for the market − and these will be dominant themes as the market continues to mature in 2026. BCB Group’s view has always been that risk and resilience are operational, immediate and systemic requirements, rather than just loose, abstract concepts. Firms can either build a strong foundation of risk and control to build trust and achieve sustainable growth, or they can move fast, prioritise growth and fix problems later on.
choose a provider based on whether they can move money around quickly − but whether this can be achieved safely, at scale and under market stress.
REGULATIONS SHAPE CRYPTO'S NEXT PHASE
You can always choose the jurisdictions with easier regulations; however, firms that operate in tougher regulatory environments tend to last longer. New regulations are accelerating this trend: MiCA rules across Europe have forced institutions to place much more emphasis on governance, safeguarding and resilience. But Sullivan warns that if you haven’t built on strong foundations, you’re not just implementing controls later — you’re fixing legacy issues, and that slows you down. Choosing the other option and focusing on risk and compliance shouldn't slow the business down − it should help it achieve its objectives more sustainably. This is fundamental to why BCB Group views risk and resilience as key drivers of innovation, not constraints. When you embed them properly into your operations − rather than treating them as standalone functions − this demonstrates you have a strong, controlled environment. That doesn't limit growth − it facilitates it by attracting better clients and longer-term relationships.
are increasingly stipulated by institutional counterparties. Sullivan reiterates that those
that treat safeguarding as a simple compliance exercise and a 'static' requirement will struggle to meet the increasingly rigorous expectations of institutional clients. It should now be seen as the key mechanism for determining whether funds are accessible, protected and recoverable during market stress. As safeguarding expectations rise, regulation is becoming an important test of resilience and the ability to mitigate risks. NEW RULES In May 2026, the FCA will introduce stronger safeguarding rules for payment institutions and e-money firms. This change is designed to protect customer funds and enable
and culture, or treat regulation as a simple afterthought and a compliance tick box exercise.
BCB has chosen the first approach. This report explores why resilience and safeguarding have become the main infrastructure challenge for institutional crypto payments − and how BLINC is designed to
Safety is no longer optional; it's a foundational requirement for financial institutions.
meet this challenge at scale. THE RISK IMPERATIVE
“Safety is no longer optional; it's a foundational requirement for financial institutions”, Sullivan says. As digital assets have evolved from the margins of finance towards widespread institutional adoption, the risk profile of this sector has
James Sullivan Chief Risk and Compliance Officer BCB Group
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