Case: B2B platform for settlements between crypto traders and investment funds

What was the client's request?

We were approached by a client with a Polish VASP company that was already operating as a B2B platform for settlements between crypto traders and investment funds.
The company served a limited number of legal entities and supported large-volume OTC transactions.
The request was to obtain a CASP license and thereby legalise its activities under the new MiCA rules, while maintaining its existing business structure.

Why couldn't the client do it on their own?

• It needed a deep understanding of Polish regulatory requirements and MiCA standards.
• The company didn't have any in-house KYC/AML and financial compliance specialists.
• Preparing the documents and financial model on their own could have led to the application being rejected due to non-compliance with the regulator's format.
• There was a lack of experience in forming the architecture of the dossier for CASP submission.

What solution did we offer and why?

We offered to prepare a comprehensive dossier for obtaining a CASP license without changing the existing structure of the company.

Our solution included:

1. Engaging Polish accountants and lawyers familiar with KNF requirements.
2. Auditing and updating financial statements, preparing a sustainability case.
3. Developing and implementing a KYC/AML system that complies with Polish regulatory standards.
4. Describing the architecture of processes — customer onboarding, reporting, transaction control.
5. Full support in submitting the application to the regulator.

This approach allowed us to maintain the legal and operational continuity of the business and increased trust on the part of partners.

Were there any difficulties in resolving the request?

The project required deep immersion in the client's existing processes:

it was necessary to rebuild the compliance structure while maintaining current business flows;
some of the documentation had to be recreated — previously, many processes existed ‘at the level of agreements’;
the regulator imposed strict requirements for financial stability, so the reporting was revised and confirmed by local auditors.

Case duration

It took four months to prepare and adapt the documents and submit the application.

What specialists were involved:

• Financial analyst;
• Compliance expert;
• EU licensing lawyer;
• Polish accountant;
• Technical consultant on KYC/AML system integration.

Result

1. A complete dossier for obtaining a CASP license was prepared.
2. The company's internal processes were brought into full compliance with MiCA.
3. Updated reporting and internal control systems proved the sustainability of the business model.
4. The application was submitted without any preliminary comments from the regulator.