Jurisdiction • European Union • MiCA

EU (MiCA): CASP licensing, token classification and compliance for crypto businesses.

MiCA (Markets in Crypto-Assets Regulation) establishes a unified EU framework for crypto-asset services and certain token issuances. If you provide crypto services in the EU (or target EU clients), you need a clear CASP route, an implementable compliance system, and documentation that matches real flows (custody, execution, fiat rails, onboarding, outsourcing).

We focus on “regulator-ready + bankable” setups — not template packs that don’t match your business model.

When MiCA becomes critical

You onboard EU clients (retail or professional).
You run exchange/brokerage/custody/transfer flows.
You market into the EU or operate from the EU.
Banks/partners ask for EU regulatory position + controls.

Often paired with Crypto licensing and Web & Crypto.

Routes

Typical MiCA engagement routes

The correct scope depends on your services (custody, execution, exchange, brokerage, transfer), client types, outsourcing and technology stack. We start with activity mapping and then lock the route.

Route

CASP licensing readiness

If you provide crypto-asset services to EU clients.

Activity mapping and CASP scope memo.
Governance and compliance design (roles & escalation).
AML/KYC + sanctions baseline (aligned to flows).
Application narrative alignment and Q&A support.

Goal: a defensible route with implementable controls.

Route

Token classification & issuance support

If you issue or list tokens and need a compliant EU narrative.

Token rights and product classification memo.
Disclosures and restrictions (jurisdictions/clients).
Exchange listing readiness pack (as needed).
Risk disclosures and marketing claims review.

Best for: utility-like models, RWA/tokenization, listings.

Route

Banking/PSP readiness

When fiat rails and counterparties drive viability.

Business narrative + flow-of-funds mapping.
AML/KYC and sanctions controls evidence trail.
Onboarding procedures and operational SOPs.
Vendor/outsourcing controls and audit readiness.

Often needed even before licensing submission.

Process

How we build a MiCA-ready setup

We start with operations and flows, then build documents and governance. This avoids “paper compliance” and reduces regulator back-and-forth.

Activity & flow mapping

Clients, jurisdictions, assets, custody responsibility, fiat rails, counterparties, outsourcing map.

CASP scope memo

Which services are triggered, what must be built (roles, controls, policies, procedures).

Governance + compliance

Compliance manual, AML/KYC, sanctions, risk, outsourcing, incident and reporting cadence.

Documents & Q&A

Client-facing docs, contracts, evidence pack; regulator/bank Q&A support.

Output is an implementable system (roles + controls + SOPs) plus a document set that reflects your real operations.

Deliverables

What we prepare for MiCA / CASP

Scope depends on the services you provide. Below is a practical baseline used for many crypto platforms and cross-border teams.

Core

CASP scope memo & gap map

A clear plan: what must exist before submission.

Services scope and assumptions.
Custody/control responsibility matrix.
Compliance and governance gaps list.
Timeline + deliverables checklist.

Best starting point for serious MiCA work.

Core

Governance & compliance manual

Roles, escalation, reporting and independence rules.

Compliance framework and responsibilities.
Policies register + reporting cadence.
Conflicts and conduct rules (as needed).
Evidence trail and audit readiness baseline.

Designed around real team structure.

Core

AML/KYC & sanctions controls

Risk-based onboarding and monitoring that works in practice.

CDD/EDD rules and client risk scoring.
SOF/SOW evidence baseline (where relevant).
Sanctions/PEP/adverse media workflow.
STR/SAR escalation + recordkeeping.

Often critical for banking and licensing.

Add-on

Risk & outsourcing framework

Operational, tech and vendor controls mapped to your stack.

Risk taxonomy + risk appetite baseline.
Outsourcing due diligence and audit rights.
Incident response and remediation plan.
Access management and monitoring logic (high level).

Where many regulator questions focus.

Add-on

Client-facing legal docs

Agreements and disclosures aligned with your services.

Client terms, risk disclosures, complaints handling.
Custody terms / safeguarding disclosures (if relevant).
Marketing claims review and restrictions logic.
Privacy and data/IT clauses baseline.

Goal: reduce legal risk and counterparty friction.

Add-on

Token classification & disclosures

For listings, tokenization and issuance-ready narratives.

Token rights memo (economic + governance).
Restrictions by client type and jurisdiction.
Risk disclosures and disclaimers pack.
Support for exchanges/partners due diligence.

Useful for RWA and token projects.

FAQ

Common questions about MiCA

Short answers. We tailor the approach to your business model, services scope, and counterparties.

Do we need CASP licensing if we are “offshore” but target EU clients?

Very often, yes — the practical trigger is whether EU clients are targeted/served and what services you provide. We start with a scope memo and map the “EU touchpoints” (marketing, onboarding, execution, custody, fiat rails).

Can we use a generic template compliance pack?

Templates usually fail in regulator/bank scrutiny because they don’t match real flows, roles, outsourcing and evidence trail. We build an implementable system aligned to your product and tech stack.

What do banks/PSPs ask for first under MiCA-style scrutiny?

AML/KYC + sanctions controls, onboarding procedures, custody responsibility clarity, counterparty mapping, and an evidence trail that your team can produce quickly.

Can you start with a “route memo” before a full engagement?

Yes. It’s the fastest way to reduce uncertainty: we map your services and propose a CASP scope, a compliance baseline, and a realistic document/workstream plan.

Need a MiCA / CASP-ready plan?

Send a short description: your services (custody/exchange/brokerage/transfer), target markets, client types, and your banking/licensing goal. We’ll propose a CASP scope memo and a practical deliverables plan.

If you already have policies, we can start with a gap analysis and update only what is missing.

Good fit for MiCA support:

Exchanges, broker-dealers, custody and wallet providers.
Crypto businesses onboarding EU clients.
Tokenization / RWA projects needing EU-ready disclosures.
Teams preparing for bank/PSP onboarding and audits.

We map controls to real flows — that’s what regulators and banks care about.