Do we need a licence?
Map the activities, control and customer relationships against the rules in the markets that matter to the business.
REGULATORY / CRYPTO BUSINESS
Know the perimeter.
Design your way forward.
A licence is one route. Product architecture, the allocation of activities and market selection can open others. I assess what your business actually does, then build a regulatory strategy around it.
Discuss your project 30-minute introductory call · Google Meet
START WITH THE BUSINESS QUESTION
Could a different architecture work?
Examine whether changes to the product or allocation of functions could lawfully change its regulatory treatment.
Where can we operate?
Compare jurisdictions against market access, operational requirements and the commercial model.
PRODUCT. BUSINESS. LAW.
The architecture
can change the answer.
Who holds the keys? Who executes a transaction? Who contracts with the customer? How does the business earn its revenue? The legal strategy starts with those mechanics.
Discuss your regulatory options ↗1. Understand the actual activity
Review the product, money and asset flows, control, user journeys and third-party integrations. Identify which entity performs each function.
2. Compare the available routes
Assess licensing and registration requirements alongside alternative structures and potentially out-of-scope models. Make the commercial implications and legal assumptions explicit.
3. Shape the operating model
Work through product design, allocation of functions, governance and jurisdiction choices with the founders and technical team.
4. Document and implement
Translate the chosen approach into a legal position, operating constraints, contracts and policies. Where a licence is required, define the authorisation work and relevant local support.
Depending on the engagement: a regulatory perimeter assessment, a comparison of viable routes, a structuring recommendation, a legal opinion, or an agreed set of licensing documents. An out-of-scope position needs a legal basis and a business that continues to operate within the assessed facts and boundaries.
BEYOND ONE JURISDICTION
One business.
Several sets of rules.
Crypto regulation, payments, AML, gaming and financial promotions can intersect in the same product. The work follows your activities and markets.
LICENSING & MARKET ACCESS
Choose a route the business can support.
Compare the relevant licensing or registration frameworks, local substance, governance and operational implications. Coordinate jurisdiction-specific work and local counsel where required.
Explore licensing support ↗REGULATORY ARCHITECTURE
Design around the real boundaries.
Assess whether a different allocation of activities, control or customer relationships can place particular services outside a licensing perimeter. Other legal obligations may still apply to the resulting business.
Explore product analysis ↗EU MARKET / MiCA
MiCA, when the EU is part of the plan.
MiCA and CASP authorisation remain part of the practice: service mapping, readiness assessment, governance and legal documentation for the proposed EU operating model.
Read my MiCA analysis ↗Can product architecture change the regulatory outcome?
It can, where the actual activities, control and relationships change in a legally relevant way. I assess the proposed model against the applicable framework and identify the conditions it would need to satisfy. A new label or a disclaimer alone does not establish an out-of-scope position.
Does every crypto business need the same licence?
The relevant requirements depend on the services, entities, customers and jurisdictions involved. A software business, a custodian, a trading platform and a gaming operator can raise different questions. That is why the work starts with the actual business model.
Do you work beyond the EU?
Yes. The practice covers cross-border regulatory strategy and business structuring. MiCA is one framework within that work. The relevant jurisdictions and any need for locally qualified counsel are identified for each project.
How are scope and fees agreed?
The scope depends on the product, jurisdictions, documents and level of support involved. We discuss the fee, deliverables and timing before substantive work begins. Send a short project overview to start that conversation.
YOUR NEXT STEP
Your model is different.
Let’s look at your options.
A 30-minute introductory conversation about your project, priorities and the scope of support you need.