FCA authorisation and operating model design
Designing operating models that work in practice, not only on paper, and carrying them through the authorisation process.
Independent regulatory consultancy
Orbyt Advisory Limited (Company No. 16843464) is an independent UK financial services regulatory consultancy based in London, founded by Tom Leyhane.
Most firms understand the regulation. The difficulty is applying it in a way that works commercially and stands up to FCA scrutiny.
Orbyt advises boards, founders and firms on how UK and EU financial services regulation translates into operating models, governance and decision-making in practice — the point at which legal advice has to be made operational.
Founder
Group Chief Compliance Officer, IG Group plc — a FTSE-listed financial services firm with over £1 billion in annual revenue, predominantly retail leveraged derivatives.
SMF16 (Compliance Oversight) and SMF17 (Money Laundering Reporting Officer), held at IG Group through to October 2025.
Led IG Group's FCA cryptoasset registration — the first secured by a UK-listed firm — through to authorisation.
Led the regulatory due diligence on IG Group's £160 million acquisition of Freetrade, advised the CEO and board on regulatory strategy and likely FCA treatment, and led the subsequent change-in-control application.
Led IG Group through FCA and ESMA regulatory interventions that materially reshaped the business.
His career began on structured products trading desks at UBS and RBS through the credit crunch and sovereign debt crisis, before moving into compliance via the FCA.
Practice areas
Designing operating models that work in practice, not only on paper, and carrying them through the authorisation process.
FCA cryptoasset authorisation and MiCA implementation, including the FCA's emerging cryptoasset regime and gateway timeline.
Accountability mapping, Statements of Responsibilities, governance frameworks and reasonable-steps support.
Framework design and implementation for business models where existing guidance does not map cleanly onto products or customer journeys.
Working alongside legal advisers through the regulatory process on transactions and corporate restructuring.
Financial crime frameworks, MLRO support, and cryptoasset registration under the MLR.
Support where decisions on growth, transactions or product design depend on how the FCA is likely to respond.
Regulatory treatment where the position is unclear or still developing in practice.
Preparing for, or responding to, supervisory visits, skilled person (s.166) reviews and enforcement action.
Who Orbyt works with
Founders and boards navigating authorisation for the first time. Established firms facing regulatory change that cuts across their business model. Law firms that need regulatory implementation expertise alongside their legal advice.
Orbyt works alongside legal advisers, not in place of them. The work begins where legal advice lands and has to be made operational — governance, controls and decision-making that work in practice. Independence from commercial product and platform interests is a fixed condition of how the firm operates.
Contact
tom@orbytadvisory.io