Most EU VASPs underestimate this about MICA

MICA license applications are finally getting accepted - it's been now confirmed that France, Italy and Ireland have begun accepting applications under the new MICA regime, at least from some participants.

A few other jurisdiction have contacted their existing VASPs and shared tentative timelines and likely application requirements.

Based on the available information, it looks like the issues around reserves and customer funds safeguarding are viewed as straightforward and do not cause any substantial ambiguities.

However, several other issues emerged that can significantly undermine licensing progress under MICA and cause delays, such as:

• to which extent? European CASPs are allowed to engage in DeFI, staking, DAO structures?and crypto lending?
• where?is the border line between MICA and MIFID with respect to hybrid crypto products and algo-trading?
• which?3rd party tokens can? be supported under MICA and for which service types (the USDT controversy among them)

To answer these questions and to help existing VASPs streamline and fast-track their re-applications under MICA I am offering a new dedicated workshop on November 7th, which is a part of the MICA Licensing for Self-Starters Package.

With this MICA Licensing package you?will get instant access to policy templates (updated for 2025), SOPs, T&Cs, checklists,? and even a sample license application document?to save you valuable time and help you focus on growing your business, building the team and keeping your regulators, partners and customers happy.?

This package also includes access to future updates for all policies and trainings.

Live Training "How to fast-track your VASP to MICA re-application process" (takes place on Nov 7th 2024):

Pre-application.?What do you need to have in place before you apply in terms of people, tech, and documentation.

Application and Post-Application. We talk specifically about key reasons why so many applications are stumbling in the beginning and how to avoid it. We share experiences on how to conduct regulatory negotiations and how to know you are on track. We cover?key milestones of the post-application phase, such as completing audits, passporting, setting up FIU, DPA, and other processes before you go live.

Most controversial issues and how to address them:

• what you can re-use vs what needs to be established when you "upgrade" from VASP to? MICA licensing;
• preparing disclosures and assessments for the tokens your platform supports;
• your relationships with DeFi projects and how to differentiate DeFi vs CeFi and relationships with DAOs;
• how to deploy staking solutions;clients funds and reserves policy;
• templates available within the package and how to use them.Q&A

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AlLSO INCLUDED:

Trainings and Workshops (pre-recorded and instantly available):

• FinTech Licensing Planning

• MICA Requirements Workshop

• End-to-end Crypto Compliance Training

• Complying with Apple and Google Appstore Guidelines for crypto startups

Templates (updated for 2025):

• FinTech Licensing?- including License Application Template, financial projections template, business plan template, FinTech licensing roadmap, first regulatory inquiry template
• AML, KYC, PEPs, sanctions policies and SOPs,?onboarding flow setup guide (including policies, tools review, and guidance on admin and case management setup)
• Privacy and GDPR module, including privacy policy, GDPR compliance policy, binding corporate rules, and standard contractual closes or Data Transfer Appendix template (to be included in all your contracts with vendors and payments partners where data transfer is involved). Digital Services Act implementation guide.
• Outsourcing?framework setup, including outsourcing policy template and outsourcing assessment checklist
• Consumer and Investor Protection, including?Customer Protection and Complaints Handling Policy, Investor Protection Policy, and Customer Funds Safeguarding Procedure?(for fiat and crypto services)
• Information Security, including InfoSec policy, incident management, and business continuity policy
• Blockchain-specific regulations, including?Blockchain Operational compliance policy?
• Corporate Governance?and Board of Directors set up, Code of Conduct, Segregation of Duties guidance, Anti-Bribery and Corruption procedure, and other relevant templates (e.g. gift policy, HR screening, etc.)
• Business-wide risk assessment?and product risk assessment (with dedicated sections for AML, Product, VASPs, General Risks, Financial Risks, Startup Risks, and Regulatory Risks)
• Risk Management, Assessment, and Fraud Prevention, including relevant Risk Management policy and Risk Assessment and Risk Assessment methodology templates
• Conflict of Interests and Insider Trading Policy
• Terms of Service, Affiliation and Loyalty Programs structuring?(including sample language for loyalty points or reward programs, beta testing provisions, and affiliation program templates)
• Inter-Company Agreements and SLAs
• Detailed and comprehensive Annual Compliance Plan and sample Internal Audit Plan.?Compliance Assurance Framework (roles of FLOD, SLOD, audit)
• Token listing and token assessment criteria?(for cryptocurrency exchanges or wallets).
• DORA-compliant disclosures
• FATCA and CRS compliance policy

Join today to get instant access to all the templates and trainings and join the LIVE session on November 7th 2024 to fast track your MICA application!