Analysis & implementation of MiCAR requirements

Initial situation

The client wants to investigate the impact of the forthcoming Markets in Crypto-Assets Regulation (MiCAR)
Currently, the financial commission business with crypto-assets is operated in cooperation with third-party providers
An impact analysis is to be conducted to identify necessary actions early and ensure timely implementation in full compliance with MiCAR requirements upon its entry into force
Furthermore, the necessary transmission of information to the competent authority in the notification procedure is to be prepared

Approach

Comprehensive analysis of the current state of the crypto-asset service, considering existing processes, systems, and the involvement of third-party providers
Detailed investigation into the specific implications of MiCAR on the financial commission business with crypto-assets
Clear definition of the desired operational state, pinpointing potentially affected departments and processes, and meticulously elaborating on the requirements set by MiCAR
Conduct a thorough GAP analysis identifying the variances between the current state and the desired state, development of strategic recommendations and a solid implementation plan
Derivation of work packages incl. creation of a detailed implementation plan
Project management and support during the implementation phase

Results

Elaboration of the concrete MiCAR implications on the existing business model
Based on the implications, workloads were allocated to the relevant departments
Specific work packages with implementation deadlines have been defined
Creation of a migration concept for the transition to the MiCAR regime
Project management and support during the implementation phase of the project
Management of external third-party providers to ensure MiCAR compliance of the company's own value chain, including contractual adjustments