Three assessments are included free. Existing assessments stay available and can be edited and re-run at no cost.
if you do not have one yet.
The firm moves e-money tokens on behalf of clients. Transfers of e-money tokens carried out for a client are payment services, and a MiCA authorisation does not cover them.
Action: Apply for a payment institution or e-money institution authorisation alongside the CASP application, or remove client-facing EMT transfers from the perimeter.
Funds held for clients must be safeguarded and any benefit arising on them belongs to the client, so keeping the interest earned on client fiat balances cannot be part of the business model.
Action: Pass the interest to clients or restructure the revenue model away from float income before filing.
Allowing clients to withdraw to an address the firm does not control is the provision of transfer services for crypto-assets on behalf of clients, and it is not covered by the custody permission alone.
Action: Add the transfer service to the application, or disable withdrawals to addresses outside the firm's control.