Crypto fundraising

Crypto fundraising

See more in the code at: 1.1.1, 2.1.1, 2.1.4, 2.2.2, 9.1.1

Crypto is a digital asset available in different forms, for example cryptocurrency and non-fungible tokens (NFTs).  

Throughout this guide we use the term ‘crypto’ to mean any form of digital asset offered or received directly or indirectly as a charitable donation.

Crypto can be invested, traded, or converted into fiat currency (currency issued by governments, such as Pounds Sterling or US Dollars) using a digital wallet and trading/exchange platform.  

The risks arising from crypto donations might differ depending on which type of crypto asset and which token you are engaging with. Furthermore, the risks may also differ depending on whether a crypto donation is received by you directly or indirectly (see below), held for a period before converting, converted to fiat currency immediately or received via an intermediary platform. 

Direct crypto donations 

When we say direct crypto donations, we mean accepting crypto donations directly into a crypto wallet that securely stores digital access codes to enable you to manage and retrieve your assets. Crypto wallets may be provided on a custodial basis, where you get an intermediary service provider to hold your private digital access key on your behalf. They can also be held on a non-custodial basis, where you hold the key.  

Indirect crypto donations 

When we say indirect crypto donations, we mean a donation is made to you in crypto, but you use one or more intermediaries to channel, process, hold and/or convert the donation for you. In this event, you only have direct access to the donation once converted to fiat currency. 

Making strategic decisions about accepting crypto  

See more in the code at: 1.1.1, 2.1.1, 2.1.4, 2.2.1, 2.2.3  

We recommend that you do not accept any crypto donation, directly or indirectly, unless you have already done the following: 

1. carried out a strategic risk assessment of crypto fundraising, 
2. evaluated whether accepting crypto donations align with your charity’s purposes and values, and 
3. your trustees have taken a strategic decision to accept crypto donations. 

This is to make sure you have adequate accountability and oversight of crypto donations and are not exposing your organisation to undue risk.  

You might be considering crypto as a source of funding because a donation has already been offered to you, or you anticipate one might be. It is understandable that this may prompt you to consider your strategic position on crypto. Even if you subsequently decide to accept such a donation, you should not do so until your trustees have agreed a crypto acceptance policy. 

If you decide to accept crypto donations, keep the decision under reasonable regular review. This will enable you to be alert to the evolving crypto landscape, including any new legislation and regulation (see below).    

Even if you have already taken a strategic decision to accept crypto, there may be times when you need to make a separate decision about accepting an individual crypto donation. Make those decisions in accordance with your crypto acceptance policy and your charity’s governing document. 

Always document your strategic decisions relating to crypto fundraising and keep adequate records of the donations you accept, refuse and return. 

See more in our guide to Documenting your fundraising decisions. 

Making informed decisions about crypto donations 

See more in the code at: 1.1.1, 2.1.1, 2.1.4, 2.2.2, 3.5.1 

Many sources of information about crypto are easily available, including how crypto works, different assets and tokens, definitions of technical terms, and the potential risks and benefits of engaging with crypto assets.  

You should gather enough information to make the right decision about whether to accept crypto donations, to avoid facing unexpected risks. In some circumstances you may need to get specialist advice, if your existing understanding of crypto is insufficient to make a reasonable decision or if your plans are complex or involve heightened risk.  

It is your responsibility to gather information and data that is accurate, up to date, and relevant to your circumstances. Be aware that some information might be imbalanced or commercially motivated and might not provide all the details you need. Some information might not consider the UK’s legal and regulatory environment, for example if it is intended for non-UK audiences.  

See our guide to Due diligence and fundraising and Documenting your fundraising decisions. 

Risk assessment 

See more in the code at: 1.1.1, 2.1.1, 2.1.4, 2.2.2, 3.5.1, 4.1.1, 6.3.1, 9.1.1  

You should carry out a risk assessment to help your trustees make a reasonable decision about whether to accept crypto. If you do not carry out a risk assessment at all, or conduct one that is insufficient for your purposes, your organisation could be exposed to harm.  

Always document your risk assessment in writing. If we were to investigate a complaint about your crypto fundraising, your risk assessment may help you to explain your actions. 

There are some well-known features of crypto that might increase the risk of this type of donation to your organisation, including for example: 

• Donor identity: Although digitally recorded, traceable, and immutable (unchangeable), the source of a crypto donation may not always be easily linked to an identifiable person. This means it may be difficult to know who has donated. 
• Financial crime: Some factors associated with crypto, including the potential anonymity of donors, could increase the risk of donations being connected to financial crime, such as money laundering, fraud, theft, sanctions evasion and other illicit activities. 
• Proscribed organisations: It may be difficult to identify if a proscribed organisation is connected to a donation. 
• Environmental and social impact: The environmental and social impact of crypto may be incompatible with your charitable purposes and values. 

Make sure you have adequate measures in place to manage or mitigate these and other risks you identify before accepting crypto. See our guides to Documenting your fundraising decisions and Due diligence and fundraising. 

Creating a crypto fundraising policy 

See more in the code at: 1.1.1, 1.2.1, 3.5.1, 4.1.1, 8.1.1 and sections 2, 6 and 9   

If you have agreed to accept crypto donations in principle - even if you do not, or rarely, receive any in practice – you should support this with an adequate crypto acceptance policy. This should set out your approach to accepting, refusing and returning crypto donations. It may be integrated into your general donations acceptance policy or be separate from it.   

You should have a policy regardless of the value of crypto donations anticipated, offered or received. This will prepare you to handle any donation appropriately, even if it is unexpected, in accordance with your policy, governing document, the code and the law.  

See our guide to Documenting your fundraising decisions and Due diligence and fundraising. 

Choosing crypto infrastructure and services 

See more in the code at: 1.1.1, 2.1.1, 2.1.4, 3.5.1, and sections 6 and 9 

The law in the UK on crypto activities is changing in 2027 when a new crypto assets regulatory regime enter into force, which is being overseen by the Financial Conduct Authority.  

This will most likely directly affect crypto asset service providers, rather than charities carrying out crypto fundraising. You may nonetheless interact with crypto asset service providers who are subject to the regulations. Where this is the case, do not knowingly engage the use of services that are not compliant with the law.   

Make sure the crypto activities you carry out, and any infrastructure services you use to support them, meet all applicable UK legal and regulatory requirements. We recommend that you get specialist advice if you need to understand more about the scope and applicability of the evolving law on crypto.  

Always read and understand the terms and conditions of any service provider you use to support your crypto fundraising before accepting them.  

Be proactive in checking whether any fundraising services you use process crypto donations by default, such as online fundraising platforms that may have activated such functionality as part of an existing service agreement. You should decide if that is compatible with your donations acceptance policy, in accordance with this guide, before using them.   

If you unknowingly accept crypto donations directly or indirectly, for example, because crypto functionality forms part of a package of services provided to you by a third party, you may find you cannot adequately: 

• meet the requirements of the code  
• uphold necessary accountability and transparency  
• carry out an adequate risk assessment, conduct due diligence and document your process and decisions, and uphold your charitable purposes and values  

We recommend that you only accept crypto donations following your proactive decision to do so, as set out in this guide.  

Whatever systems and services you use to accept crypto donations, do not forget to close, delete or deactivate them if you decide to no longer accept crypto. For example, if you have previously held a crypto wallet but decide to stop accepting crypto, you should empty and delete (or equivalent) the wallet to avoid any further donations being made.  

See our guide to Handling cashless donations 

Staff and volunteer training 

See the code at: 1.1.1, 1.2.1, 2.1.1, 2.2.2, 3.5.1, 4.1.1, 5.2.1, 6.1.1, and 8.1 

You should train your relevant staff and on behalf of volunteers, which may include trustees, if they will be involved in crypto fundraising. This is to provide them with adequate knowledge, skill, and ability to communicate, process and manage crypto donations as relevant to their role. You may have enough internal knowledge to provide training in-house, but if not, you may need to get external training provision.  

Training should include, but may not be limited to: 

• Technical terms: Using relevant language and terminology accurately when engaging with others about crypto.  
• Systems and platforms: Using infrastructure systems and platforms correctly and appropriately. 
• Returns: Knowing your process to return donations originally made in crypto.  
• Financial crime awareness: Understanding the range of risks, such as money laundering, that may apply to crypto donations. 
• Cyber security: Applying the correct security and controls on crypto infrastructure, such as crypto wallets. 

See more in our Key behaviours expected of fundraisers: guidance for fundraisers

Due diligence on crypto donations

See the code at: 1.1.1, 2.1.4, 2.2.2, 2.2.3, 5.2.3 

Due diligence should be carried out on all donations whenever your risk assessment indicates it is needed. This is to make sure you are compliant with anti-money laundering legislation and are protecting your charitable fundraising institution from other financial, legal and reputational risks.   

You are responsible for ensuring adequate due diligence is carried out, including when you are using third-party service providers.  

Make sure you and any third-party services you use for the purposes of receiving and processing crypto donations, are equipped to carry out adequate due diligence on your behalf before accepting crypto donations.  

Due diligence in relation to crypto should be carried out, at a minimum, on the following occasions: 

• when considering which crypto infrastructure services to use,  
• on individual crypto donations where appropriate, and 
• for any other purpose where it is reasonably required.  

You should document the process you follow, your findings, decisions and the actions you take. 

Crypto assets are not recognised as currency in the UK. They are not eligible for Gift Aid. Neither do they have the same legal, regulatory, or process infrastructure as banks and other traditional mechanisms for financial transactions. This means the risk environment relating to crypto assets requires stronger due diligence for individual donations, compared to other types of charitable donation. 

Always keep adequate records of your crypto donations, whether they are received directly or indirectly (see above). 

If there are ever circumstances where you need to report a serious incident relating to crypto fundraising to the relevant charity regulator in England and Wales, Northern Ireland, or Scotland, you should also self-report the matter to the Fundraising Regulator.  

See our guides to Due diligence and fundraising, Monitoring your fundraising partners and Documenting your fundraising decisions.

Promoting crypto donations to supporters 

See more in the code at: 1.2.1; 1.2.6; 2.1.1; 2.1.5; 7.5.1, and section 8

If you have decided to accept crypto, be transparent with donors about your crypto acceptance policy and procedures. This includes describing the key features of your policy anywhere you promote or provide the opportunity to donate crypto, such as if you do not accept anonymous donations or only certain types of crypto asset. 

If you promote the opportunity to donate crypto while hosting or attending events, this will amount to a fundraising event. Find out more in our guide to Fundraising events. If you promote the opportunity to donate crypto on social media, find out more in our guide to Fundraising on social media.  

If you promote the opportunity to donate crypto to another charitable fundraising institution, be transparent with donors about the:

• recipient organisation's name and charity registration number (or equivalent)
• jurisdiction it is registered in for legal and regulatory purposes
• purposes of the fundraising
• recipient being an organisation other than your own
• relationship you have with the recipient organisation 

You might be promoting crypto fundraising for another organisation because, for example, you have entered into a fundraising partnership with them, or you have aspects of connected governance. If you have a separate legal identity for fundraising purposes, you should not imply, through act or omission, that a crypto donation is for you when it is for another organisation.