course content
25/09/2025 15:00 - 18:15
02/10/2025 15:00 - 18:15
16/10/2025 15:00 - 18:15
23/10/2025 15:00 - 18:15
Module 1: EU-Level Legal Foundation and Classification of Crypto-Assets
- Introduction to the Digital Finance Strategy and regulatory rationale for MiCA
- Scope and exclusions: What MiCA regulates vs. MiFID II (tokenised securities), e-money, and NFTs
- Classification under MiCA: EMTs, ARTs, and other crypto-assets
- Practical implications of asset classification: who needs to comply and how
- Transitional timeline and MiCA’s phased implementation (2023–2026)
- Workshop: Participants will map out key compliance milestones from 2023 to 2026 and present a strategic transition plan for a hypothetical Cypriot CASP, including preparation steps for licensing and supervision.
- Discussion: Evaluate the pros and cons of the transitional period and how Cyprus’s full 18-month grandfathering affects market entry and competition.
Module 2: Cyprus Implementation – CySEC, Legal Mandate, and Licensing Timeline
- CySEC as the national competent authority: national law amendments to AML Law
- Transition from the pre-MiCA CySEC CASP register to full MiCA authorisation
- Domestic penalties for non-compliance: administrative and criminal exposure
- Transitional arrangements for Cyprus CASPs and notification deadlines
- Overview of the CySEC licensing application process and preliminary submissions
- Discussion: Compare the documentation and governance requirements for a typical CASP license application with those required for a CIF under MiFID II. Explore how MiCA's substance and capital requirements challenge startup entrants.
Module 3: CASP Licensing, Requirements, and Supervision under MiCA
- CASP service categories and their regulatory implications
- Classes of CASP licenses and initial capital requirements (€50k–€150k)
- Application structure: governance, EU presence, business plan, policies
- CySEC’s supervisory fees, annual reporting, and internal audit expectations.
- Internal substance: fit and proper tests, board structure, MLRO, CCO
- CySEC’s preliminary application process and assessment timelines
- Case Study - Participants will review a redacted preliminary application submitted by a Cypriot crypto startup. In small groups, they will identify strengths and weaknesses in the documentation and propose revisions to ensure the application would meet MiCA’s governance, capital, and internal control expectations.
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Module 4: Enforcement, Market Integrity, and EU Enforcement Trends
- Market abuse rules under MiCA: insider dealing, unlawful disclosure, and manipulation
- CySEC enforcement priorities and new penalties under the Cyprus AML Law
- Case examples - Coinbase and Binance fines in the EU
- Transition supervision: CySEC’s demand for proof of compliance by January 2025
Module 5: Designing an Internal Compliance Programme
- Structuring policies on custody, IT security, governance, and conflict of interest
- Risk management frameworks for MiCA compliance
- Safeguarding client assets and ensuring liquidity of ART/EMT reserves
- Outsourcing requirements and continuity planning under MiCA
- ESG disclosures, white paper preparation, and investor communications
Module 6: Case Studies, Cross-Regulatory Issues, and Strategic Planning
- Cyprus case studies - MiCA transition by Cypriot CASPs, operational hurdles, and best practices
- Intersection with PSD2 (payment services), GDPR, AML, and tax reporting (CARF)
- DeFi, NFTs, and borderline use cases under MiCA
- Strategic planning for CASPs: licensing choices, product limitations, and compliance roadmap
- Case Study - Analyse the business model and service roadmap of a hypothetical CASP seeking to expand from Cyprus to the wider EU. Identify how MiCA licensing choices (e.g., Class 1 vs. Class 3) affect operational strategy and compliance costs.
- Q&A - What are the key strategic decisions a CASP must make when structuring their application under MiCA? How should product limitations or regulatory uncertainty be factored into expansion plans?
This course is aimed at professionals employed in law firms, compliance departments, financial institutions, crypto-asset service providers (CASPs), or regulatory bodies who are involved in legal, regulatory, or supervisory work related to crypto-assets and digital finance.
Indicative job roles or responsibilities include:
- Legal advisors or associates working on CASP licensing and regulatory compliance Compliance
- Officers responsible for risk management, AML/CFT, and reporting under MiCA, Regulatory staff or consultants supporting clients in CySEC submissions or white paper preparation, Legal executives or professionals involved in drafting internal policies for crypto firms
- Risk or governance professionals involved in digital asset business models and strategic compliance planning