Case: Preparing a crypto exchange for CASP licensing under MiCA standards

What was the client's request?

The client is an operating P2P crypto exchange with a VASP license and its own infrastructure:

• an automated exchange platform between users;
• built-in wallets;
• an internal verification system (KYC).

The company was already operating successfully in the market, but with the entry into force of the MiCA regulation, it became necessary to obtain CASP status in order to continue operating in the EU, increase trust among partners, and connect European banking solutions.

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

1. The new MiCA regulation required a complete overhaul of compliance and IT processes.
2. To apply in Poland, they needed a physical office and local staff (director, compliance officer).
3. A thorough adaptation of AML/KYC policies and regulations to KNF (Polish regulator) standards was necessary.
4. Errors in preparation could have led to the application being rejected or operations being suspended.

What solution did we offer and why?

1. We offered comprehensive turnkey preparation while maintaining the client's operating model:
2. Process analysis and audit — detailed review of KYC/AML, IT infrastructure, and internal reporting.
3. Organisation of local presence — outsourcing of office address and selection of mandatory employees.
4. Development of a regulatory package — adaptation of internal documentation to MiCA and KNF requirements.
5. Preparation and submission of an application — full support in preparing the dossier, including a business plan, financial model, and IT security documents.

Were there any difficulties in resolving the request?

• Maintaining a balance between the existing company structure and MiCA requirements.
• It was necessary to synchronise legal and technical processes so as not to interrupt current operations on the platform.
• Remote coordination between several countries required constant monitoring of deadlines and statuses.

Case duration

4 months — from the start of the audit to the submission of the application to the regulator.

What specialists were involved?

• a lawyer specialising in crypto licensing (MiCA/CASP);
• an expert in KYC/AML and internal control;
• an IT consultant on information security;
• an accountant and financial analyst to prepare the financial model.

Result

1. The complete set of documents was submitted to the regulator without preliminary comments.
2. The company retained its existing structure and did not interrupt its activities.
3. The platform was able to continue operating legally in the EU and expand its partner network.