FCA Compliance Consultant Required

I need a specialist to advise on 2 matters:

1 - FCA Crypto Regulations

I have a client who manages a significant amount of Crypto Assets which are held in an offshore trust. The management is via a trust instrument rather than on a commercial basis. They would like an opinion on whether they are required to register under the FCA's new regime on Crypto businesses. My laypersons opinion is that they are nowhere near the regulations. It fails the first test as they are not managing the assets under a commercial agreement.

https://www.fca.org.uk/firms/financial-crime/cryptoassets-aml-ctf-regime
https://www.fca.org.uk/cryptoassets-aml-ctf-regime/register
https://psplab.com/crypto-license-uk-fca-crypto-registration-aml-ctf-regime/

2 - FCA Registration from BVI Company

I have a BVI register business which introduces clients to a regulated FX Broker (IC Markets) and a Trader for which we charge a fee. We do not give advice or hold money or hold ourselves out to do either. I would like an opinion on whether any registration is required and what disclaimers are required.