Crypto & Web3 · Licensing
EU market access under MiCA, sequenced so the banking held
A crypto exchange operating outside the EU wanted to serve EU customers lawfully, which under MiCA means a Crypto-Asset Service Provider authorisation. The founder understood the licence was required; what was unclear was which EU jurisdiction to authorise in, and the wrong answer there is expensive to undo.
The trap the operator wanted to avoid is common: authorise in whichever member state grants a CASP fastest and cheapest, then discover the settlement banking for that jurisdiction is hard, and end up authorised but unable to actually move money.
What was actually brokenThe binding constraint on a MiCA build is rarely the authorisation itself. It is whether the banking partners a CASP needs will accept an entity licensed in that particular member state. Several operators choose a jurisdiction on approval speed and then spend longer, and more, solving a banking problem they created at the licensing stage.
The capital tier, the MLRO appointment, and the local-substance requirements also had to match the specific services the exchange intended to offer, because a CASP scoped to the wrong service set is a slower, costlier correction after the fact than getting it right before filing.
The route we placedJurisdiction and structure type only. We never name the institutions involved.
- 1
We advised on the CASP jurisdiction by banking recognition first, choosing a member state whose authorisation the exchange's prospective banking partners accept without additional friction, rather than the fastest headline approval.
- 2
We sequenced the capital, MLRO and local-substance requirements to the CASP tier for the exact services the exchange would offer, so the authorisation matched the business rather than a generic template.
- 3
We prepared the banking application in parallel with the final stage of authorisation, so an account could open in the weeks after the licence was granted rather than starting the search from zero once the CASP was in hand.
Jurisdiction chosen for banking, authorisation and banking sequenced to land together.
Weeks 1-2
Jurisdiction and scope call
Compared CASP jurisdictions on banking recognition, not just approval speed, and scoped the authorisation to the exact services the exchange would offer.
Weeks 3-10
CASP application managed
Filed and managed the CASP application, with capital, MLRO and local substance sequenced to the chosen tier.
Weeks 9-11
Banking pre-application
Prepared the settlement-banking pack in parallel with the final authorisation stage, so the file was ready the moment the licence was granted.
Post-grant, weeks 1-4
Banked and passporting live
Opened EU settlement banking within four weeks of authorisation and passported services across the EU on the CASP.
- Prior applications
- None, advised before filing
- EU market access
- MiCA CASP, passported across the EU
- Time to banked, post-grant
- 4 weeks
- Wasted licensing cost
- None, jurisdiction chosen for banking upfront
- CASP licence under MiCACapital tiers, passporting and the transitional deadline.
- Crypto licence in LithuaniaOne of the EU CASP routes we sequence for banking.
- Licensing serviceThe licences that make banking and processing possible.
- Crypto Licence Cost CalculatorJurisdiction and activity to a cost band and capital floor.
This operator’s profile is not yours. The check tells you what YOUR route looks like.
You tell us your situation in a line or two.
A person reads it the same day. Not a bot.
You get a written answer within 48 hours, under NDA.
Free pre-approval check
Tell us where it hurts. A written read on your options in 48 hours.