Pre-study on regulatory roles, development TOM for tokenized funds & license application

Tier 1 - Asset Manager

Initial situation

  • The client's objective is to analyze the potential for assuming various regulatory roles in line with the possibilities in German legislation. The following roles are examined: Crypto custodian, crypto securities registrar for tokenized funds, central registrar for electronic funds
  • The aim is to assess relevance for the current business model, derive potential target operating model (TOM) options based on this assessment, and prepare an action recommendation for the board of directors.
  • Based on the results, a decision is to be made for one or more roles. Subsequently, a concrete TOM, including the new role(s), is to be developed
  • At the same time, initial preparations for the necessary additional BaFin license applications are to be started

Approach

  • Detailed exploration of each regulatory role and clarification of the respective responsibilities, requirements and obligations under German legislation
  • Identification and assessment of the potential benefits and opportunities, as well as potential regulatory and operational risks, that could arise from taking on each role
  • Processes & IT: Derivation of relevant changes in the processes by comparing them with the current state as well as designing new processes; selection of a suitable IT solution and creation of a detailed IT target architecture, incl. make/buy/partner options
  • Governance & HR: Definition of tasks arising from the new role and development of evaluation criteria to assess the suitability of internal units to assume it; identification of personnel and competency requirements for its successful execution
  • Preparation of a draft application of authorization for the crypto securities registry

Results

  • Development of a comprehensive target operating model for both roles, incorporating critical dimensions such as processes, IT, governance and HR, complemented by a business case analysis to ensure strategic alignment, operational efficiency and measurable value creation
  • Preparation of a discussion paper to facilitate structured engagement and alignment with the competent authority
  • Draft of a license application for the crypto securities register