SERVICE 02 / CASP AML
From Regulatory Preparation to Post-Transition Compliance
CASP authorisation requires more than submitting an application.
01 / OVERVIEW
MiCA establishes requirements covering governance, prudential safeguards, management, internal controls, risk management, business continuity, ICT arrangements and other operational matters.
ESMA's Article 62 materials identify, among other things, the programme of operations, governance arrangements, prudential safeguards, management-body information, internal controls, AML/CFT risk controls, business continuity and ICT security information as components of the authorisation framework.
02 / HOW WE CAN HELP
Our support can include
- Authorisation-readiness assessment
- Business-model documentation
- Programme of operations
- Governance framework
- Management responsibilities
- Risk-management framework
- AML/CFT framework
- Internal policies and procedures
- ICT and security documentation
- Business continuity arrangements
- Outsourcing framework
- Client-asset protection arrangements
- Regulatory documentation management
03 / IN FOCUS
MiCA Transition
MiCA Article 143(3) allowed certain crypto-asset service providers that were lawfully providing services before 30 December 2024 to continue under transitional arrangements until 1 July 2026 at the latest, or until authorisation was granted or refused, whichever occurred earlier. Member States could shorten or disapply the transition.
The maximum transition date has now passed.
The CSSF has stated that from 1 July 2026, providers are no longer permitted to offer relevant services without CASP authorisation, subject to the applicable legal framework.
04 / IN FOCUS
Post-Transition Review
We can help businesses and market participants assess:
- Previous national regulatory status
- Applicable transition arrangements
- Transition expiry
- Current authorisation status
- Services being offered
- Public regulatory claims
- Relevant competent authority
- Available official register information
CASP Authorisation & Transition