We assist crypto-asset exchanges, brokers, custodians, and trading platforms with their Bafin CASP authorization under MiCA, as well as the ongoing AML compliance work required. This includes travel rule implementation, KYC, and the design and roll-out of the internal policies that Bafin expects to see.
We assess token structures under MiCA and assist with the drafting and notification of whitepapers for asset-referenced tokens, e-money tokens, and other crypto-assets. We have supported first-wave whitepaper filings for issuers including BMEX and Fanpla.
Most CASP mandates touch more than one regime. We combine CASP with adjacent Bafin licenses such as ZAG for payment services, EMT issuance for stablecoins, or KAGB and WPIG setups for asset-management components. With offices in Germany, Switzerland, and the US, we run cross-border structures as one engagement rather than coordinating across firms.
A structured regulatory assessment of your business model under MiCA and adjacent EU regimes. We work out which CASP services are in scope, which class and which capital floor applies, whether adjacent licenses such as EMT, ZAG, KAGB, or WpIG are also triggered, and in which Member State the application is best filed.
Founders and teams setting up a CASP in Germany or in another EU Member State, as well as existing VASPs preparing for the MiCA transition. We work with crypto-native firms and traditional financial institutions to add crypto services.
A partner-signed memo with classification of the service perimeter, a defensible jurisdiction recommendation, a gap analysis on your existing entity, and a roadmap to authorization. After delivery of the memo, we will walk you through it on a 60-minute call so you can make a go/no-go decision.
Once the preparatory documents are with us, the memo will be delivered within 10 business days.
A defined flat fee. The exact amount is agreed in the engagement letter. We share it as part of the introductory call so it can be discussed in the context of your specific scope.
CASPs fall into one of three classes under MiCA, with different capital floors and prudential expectations. Real own-funds requirements are set on top of these floors based on activity volumes.
|
Class |
Services in scope |
Minimum capital |
| Class 1 | Investment advice, order transmission, execution, placement, portfolio management | EUR 50,000 |
| Class 2 | Custody and administration of crypto-assets, exchange of crypto-assets for fiat or other crypto-assets | EUR 125,000 |
| Class 3 | Operation of a trading platform for crypto-assets | EUR 150,000 |
We have been working with crypto-native and traditional financial firms since 2016. More than ten dedicated specialists in the crypto team. Three jurisdictions, seven offices. Co-authors of the Chambers FinTech 2026 Germany chapter.
Crypto moves notoriously fast. We are personal users of blockchain technology because we are genuinely interested in the future. We hold tokens, interact with DeFi, and act as keyholders of tzBTC. Where needed, we help build a bridge to the traditional financial world, because most of our clients are already there.
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We’re a growing team of 30+ legal professionals. Some of our experts include:
