Android app currently not available in Google Play in UK

[SomberNight]

We received the following in email, as a warning on 2024-08-29, and then again as being enforced on Sep 28:

Action Required: Your app is not compliant with Google Play Policies (Electrum Bitcoin Wallet)

email text

Hi Developers at Electrum Technologies GmbH,

After a recent review, we found that your app Electrum Bitcoin Wallet (org.electrum.electrum) is not compliant with one or more of our Developer Program Policies. See below for more information about your app's status and how to correct the issue.
Publishing Status 	
Status: Further action required

Your app may become unavailable to Google Play users in some countries/regions if you do not resolve the issue(s) by the deadlines listed below.
	
Issue found: Violation of Blockchain-based Content policy

The purchase, holding, or exchange of cryptocurrencies should be conducted through certified services in regulated jurisdictions. Your app has not met these requirements in accordance with the Blockchain-based Content policy.
Your app may become unavailable to Google Play users in United Kingdom on September 12, 2024, if this issue is not resolved. However, this will not affect the status of your app in other countries.

To bring your app into compliance, follow these steps:

    Contact the relevant local regulatory authority to obtain the requisite license confirming your authorization to deal in the purchase, holding, or exchange of cryptocurrencies in the country.
        Contact the Financial Conduct Authority (FCA) to obtain the requisite license and/or authorization to carry out specific cryptoasset activities in the UK.
    Once you obtain the license and/or authorization document from relevant local authorities, submit an appeal through your Play Developer Console. You can attach and send the document after the appeal case has been created.

About the Blockchain-based Content policy

The purchase, holding, or exchange of cryptocurrencies should be conducted through certified services in regulated jurisdictions.

You must comply with applicable regulations for any region or country that your app targets and avoid publishing your app where your products and services are prohibited.

Google Play may request you to provide additional information or documents regarding your compliance with any applicable regulatory or licensing requirements.
Contact support
If you've reviewed the policy and feel our decision may have been in error, please reach out to our policy support team. We'll get back to you within 2 business days.
Learn More

Visit the Android Developers Blog to learn more about free tools and resources for building safe and successful apps. Check out the latest Google Play policy updates on Full Screen Intent Permission, Health Apps, Photo and Video Permissions, AI-Generated Content, and more! Watch now: #PolicyBytes

Thanks for your continued support in helping to make Google Play a positive experience for both developers and consumers.

Please complete a two question survey to help us improve this experience.
The Google Play Team

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The UK FCA provides guidance regarding who needs to register here:
https://www.fca.org.uk/firms/cryptoassets-aml-ctf-regime/registering

In particular, see their flowchart:
https://www.fca.org.uk/publication/documents/cryptoasset-registration-flowchart.pdf

As our application

• does not allow exchanging cryptoassets for money, or one cryptoasset for another cryptoasset,
• does not provide custodian services,

according to the FCA flowchart, we do not need to register with them.

We tried to explain as such to Google Play "support" and sent an "appeal" soon after the first warning email, but that appeal is still pending in status "appeal submitted" without any response, and now the app is not available for users with a google account country set to the United Kingdom.

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One of the reasons I am opening this issue here is in hope that other wallet developers getting the same emails find this.