Licence strategy, applications and regulator engagement for gaming, payments, e-money, investment and crypto-asset businesses.
Industry 03
Crypto & Digital Assets
Authorisation, token classification and compliance for crypto-asset businesses operating under MiCA and comparable regimes worldwide.
Topics: MiCA / CASPToken classificationTravel ruleCustody
Who we advise
- Exchanges, brokers and OTC desks
- Custodians and wallet providers
- Token issuers and tokenisation platforms
- Payment businesses using stablecoins
- Web3 and blockchain gaming projects
Specialisations
Business models we advise
- 01CASP / VASP
- Authorisation as a crypto-asset service provider under MiCA, or as a virtual asset service provider under national regimes.
- 02Crypto Exchanges
- Exchange and trading platform licensing, market conduct, listing policies and custody arrangements.
- 03Custody
- Custody and safekeeping of client crypto-assets: segregation, key management and liability.
- 04Wallets
- Custodial and non-custodial wallet models, and where the regulatory perimeter sits for each.
- 05Token Projects
- Token classification, white papers and offering rules for issuers and tokenisation projects.
- 06MiCA
- Authorisation, white papers, marketing communications and ongoing obligations under the EU Markets in Crypto-Assets Regulation.
- 07Crypto Payments
- Crypto payment acceptance, stablecoin flows and the payment and e-money rules that can apply to them.
Context
The regulatory landscape
Crypto-asset regulation has moved from registration regimes to full authorisation frameworks. In the EU, MiCA established a harmonised regime for crypto-asset service providers and issuers; other financial centres have built their own dedicated frameworks, each with distinct expectations on governance, custody and market conduct.
We advise exchanges, brokers, custodians, wallet providers, token issuers and digital asset platforms on classification, licensing, structuring and the compliance obligations that follow authorisation.
Challenges
Where businesses need support
- 1.
Token classification
Determining whether a token is a crypto-asset, e-money token, asset-referenced token or financial instrument.
- 2.
Licensing route
Choosing between frameworks such as MiCA, VARA, ADGM and others based on target clients and services.
- 3.
Custody and segregation
Safeguarding client crypto-assets, key management and the related operational and legal documentation.
- 4.
Travel rule and AML
Implementing information requirements for crypto-asset transfers and effective blockchain analytics.
- 5.
Banking and fiat access
Fiat on- and off-ramps and bank relationships for crypto-native businesses.
- 6.
Market conduct
White papers, marketing communications and market abuse rules for issuers and service providers.
Services
How we help
Group architecture, incorporation, substance and governance built around your licences, banking and investors.
Bank account opening, merchant account and acquiring setup, payment flows and safeguarding for businesses banks consider high-risk.
AML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.
Regulatory, business model, perimeter, payment, gaming, crypto-asset and cross-border opinions for banks, partners and investors.
Information security compliance, security governance and policies, gap assessments, DORA, NIS2, vendor risk and incident governance.
Market prioritisation, regulatory roadmaps and launch readiness for businesses expanding into new jurisdictions.
Jurisdictions
Relevant frameworks
Europe16
- EUEU / MiCACrypto-asset service providers (MiCA) · Asset-referenced and e-money token issuers (MiCA)
- CYCyprusMiCA CASP authorisation
- CZCzech RepublicMiCA CASP authorisation
- EEEstoniaMiCA CASP authorisation
- FIFinlandMiCA CASP authorisation
- DEGermanyMiCA CASP authorisation
- ITItalyMiCA CASP authorisation
- LVLatviaMiCA CASP authorisation
- LILiechtensteinTT service provider registration (TVTG)
- LTLithuaniaMiCA CASP authorisation
- MTMaltaMiCA CASP authorisation
- PLPolandCrypto-asset services (MiCA)
- PTPortugalCrypto-asset services (MiCA)
- ESSpainMiCA CASP authorisation
- CHSwitzerlandDLT trading facility licence · SRO affiliation
- GBUnited KingdomCryptoasset registration
Asia & Middle East4
Americas & Caribbean6
- VGBritish Virgin IslandsVASP registration
- CACanadaMSB / FMSB registration · Crypto trading platform registration
- SVEl SalvadorDigital asset service provider registration · Digital asset issuance · Bitcoin service provider registration
- LCSaint LuciaVirtual asset business registration
- VCSaint Vincent and the GrenadinesVirtual asset business registration
- USUnited StatesMSB registration and money transmitter licences · New York virtual currency licence
Insights
Related analysis
Regulatory update
After the MiCA transition: what crypto-asset service providers should now have in place
With transitional periods over, the question for CASPs serving EU clients is no longer whether to seek authorisation, but whether their operating model matches what they were authorised to do.
6 min read
Practice note
Building a bankable file: how high-risk businesses are assessed by acquirers and banks
Onboarding rejections are rarely explained. Understanding how a financial institution's compliance team reads your file is the most reliable way to improve the outcome.
6 min read
Questions
Frequently asked
Does MiCA apply to us if we are based outside the EU?
MiCA applies to crypto-asset services provided to clients in the EU. Firms based elsewhere generally need authorisation in a member state to serve EU clients, subject to a narrow reverse solicitation exemption that regulators interpret restrictively.
Discuss your matter with a senior advisor.
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