ECOVIS ProventusLaw brings a curated selection of significant developments from the European crypto regulatory landscape. It provides viewers with a look at what’s ahead and high-profile insights into the ever-changing crypto industry.
Interim MiCA Register
Multiple Crypto Asset White Papers approved from January to March 2025 following thorough review process:
1.SKYGATE Token (SKYG) by Skygate Network GmbH (at)
2. NIL Token by Nillion Association (com)
3. LandWolf Token (WOLF) by Dot Vision Ltd (com)
4. Acurast Token (ACU) by Acurast Association (com)
5. ONDOAI Token by OndoAI Technology Ltd. (org)
6. Abloxx Token by Abloxx Token Ltd. (com)
7. AVAXAI Token by Aivalanche LLC (avaxai.org)
8. KERNEL Token by Evercrest Technologies
9. OBOL Token by Obol Association Whitepaper
10. TOTO Token by Tiamonds AG (com)
11. AQOS Token by Progress Malta Ltd (mt)
12. NAEST Token by NAEST (io)
13. LCX Token,
Bitcoin (BTC),
Cardano (ADA),
Ethereum (ETH),
Ripple (XRP),
Hedera (HBAR),
Solana (SOL) by LCX AG (lcx.com)
14. FortressCoin (XFC) by LCX AG / SwissFortress AG (com)
15. WCT Token by WalletConnect Limited (network)
16. DGRX Token by DGRX Sales GmbH (io)
17. Triple O Token (OOO) by OUT OF OFFICE GAMES S.L. (com)
18. GEMx Token by GEMx AG (com)
From January to March 2025, the following entities were registered in the EU MiCA Electronic Money Token (EMT) Registry:
1. StablR Ltd (com)
2. SALVUS (io)
3. Ambr Payments, UAB (com)
4. Stable mint Ltd (io)
From January to March 2025, the following entities were registered as Crypto-Asset Service Providers (CASPs) under MiCA authorisation:
1. eToro (Europe) Ltd / Cyprus / etoro.com
2. Boerse Stuttgart Digital Custody GmbH / Germany / bsdigital.com
3. Bitpanda Asset Management GmbH / Germany / bitpanda.com
4. Crypto Finance (Deutschland) GmbH / Germany /crypto-finance.com/germany/de/
5. OKCoin Europe Limited / Malta / okx.com
6. BP23 CA Limited (Bitpanda) / Malta / bitpanda.com
7. Foris DAX MT Limited (Crypto.com) / Malta / Crypto.com
8. ZillionBits Limited (ZBX) / Malta / zbx.com
9. Clearstream Banking S.A. / Luxembourg / https://www.clearstream.com/clearstream-en/
10. Banco Bilbao Vizcaya Argentaria S.A. (BBVA) / Spain / bbva.es
11. Tradias GmbH / Germany / tradias.de
12. Altarius Asset Management Limited / Malta / altariusgroup.com
From January to March 2025, the following entities were issued Regulatory Notices for non-compliance:
1. Dobibo (https://dobibo.com https://dobibo1.com https://dobibo2.com)
2. Fameexn (https://fameexn.top https://fameexn.com)
3. Spazio Finanziario (spaziofinanziario.com)
4. HTXcoin-az (https://m.htxcoin-az.com)
5. Stock Credit Wallet (https://stockcreditwallet.com)
6. top – Paycraftn.top (https://paycraftv.top https://paycraftn.top)
7. CoinBank Exchange – (https://coinbankexchange.icu)
8. AKQ (https://akqa715.it https://AKQ1181.it)
9. Fameexn (https://fameexe.top https://fameexj.top)
10. ArgonInternational (https://argonintgroup.com https://cfd.argonintgroup.com)
11. Deroka UAB (https://dtcoin.tech https://dtwallet.io https://forcedmarketcap.tech)
12. DTSocialize Holding PLC (https://dtsmoney.com https://portal.dtsmoney.com)
Get familiar with newly authorised entities and those issued regulatory notices to ensure collaboration with compliant businesses.
ESMA Clarifies CASP Agent Restrictions Under MiCA
The European Securities and Markets Authority (ESMA) has confirmed that crypto-asset service providers (CASPs) cannot appoint agents to deliver crypto-asset services on their behalf under the Markets in Crypto-Assets Regulation (MiCA).
- No tied agent regime: Unlike MiFID II, MiCA does not allow agents to act on behalf of CASPs by receiving/transmitting orders or providing advice.
- Direct authorisation required: Only authorised CASPs or financial institutions that meet specific notification requirements (Article 60) may offer services in the EU.
- Independent authorisation mandatory: Any third party intending to provide crypto-asset services must obtain its own CASP licence.
Lithuania Tightens Scrutiny of Crypto Licence Applications Amid Security Concerns
The Bank of Lithuania has flagged a high rejection rate of cryptocurrency service provider licence applications due to incomplete submissions, particularly missing documents for assessing shareholders and managers.
While over ten applications were received, most were returned for revision due to the failure to provide key documentation such as certificates of good repute and proof of funds. The Bank has stressed that all applicants must demonstrate transparency and reliability, especially in light of national security concerns linked to individuals with Russian ties.
Key Points:
- Licensing gaps: Most crypto licence applications were incomplete and returned for revision.
- Essential documents: Applicants must submit certificates of good repute from both citizenship and residence countries, and provide well-documented fund origins.
- Security focus: Heightened scrutiny follows the 2025 National Security Threat Assessment, citing risks from failed investments linked to Russia.
- EU-wide implications: Since Lithuanian-licensed CASPs can operate EU-wide, strict standards are crucial to uphold financial integrity.
ESMA Clarifies When Crypto-Assets Fall Under MiFID II
Crypto-assets will be regulated as financial instruments under MiFID II if they function like securities, derivatives, or money-market instruments—regardless of whether they are tokenised or labelled as utility tokens.
According to the European Securities and Markets Authority (ESMA), classification depends on the crypto-asset’s actual economic structure and rights. Tokens that offer financial returns, synthetic exposure to assets, or resemble tradable securities may fall under MiFID II rules.
Key points:
- Function Over Form: Labels like “utility token” do not exempt an asset from regulation if it behaves like a financial instrument.
- Fractionalised NFTs may lose their uniqueness and qualify as securities.
- Tradability matters: A crypto-asset doesn’t need to be on a traditional exchange—being transferable and traded in capital market-like environments is enough.
- Tokens mimicking financial products, such as savings tokens or synthetic derivatives, may fall under MiFID II.
Bank of Lithuania Highlights MiCA Transition Period Restrictions
The MiCA transition period imposes strict limitations on cryptocurrency service providers, requiring compliance with legal requirements.
Limited Operations: Providers can only operate under the national transitional regime in their registered country. Cross-border services require a MiCA license—registration in one EU state does not grant EU-wide rights.
Regulatory Deadline: ARTs and EMTs must comply with MiCA from 30 June 2024. ESMA reaffirmed on 17 January 2025 that non-compliant assets must not be offered, and providers must inform investors.
Lithuania’s Approach: While MiCA took effect on 30 December 2024, Lithuania allows temporary operations under current rules. However, to continue business, all providers must obtain a MiCA-compliant license by 1 June 2025.
If you choose another EU jurisdiction to operate your CASP-licensed company under the new MICA Regulation, you must properly liquidate the Lithuanian VASP company.
All Lithuanian-registered VASP (Crypto) companies are allowed to operate until June 1, 2025. To continue operating after June 1, every company must get a new MICA license.
The company liquidation process may take 6 months. To start it, a company liquidator (qualified individual) needs to be appointed.
A company liquidator from a reputable law firm will represent the company to the Financial Crime Investigation Service (FNTT), supervising all Lithuanian registered VASPs and answering all regulatory questions. This will allow you to avoid possible regulatory sanctions and bad records in the Lithuanian Company Registrar.
ECOVIS will provide you with the experienced liquidator able:
- organise proper company liquidation process
- prepare 2024 annual financial statements
- review all company documentation
- settle all company debts
- terminate all employment contracts
- represent the company during all liquidation process
- complete the liquidation process and reregister the company from the registrar
Please get in touch with ECOVIS ProventusLaw for VASP company liquidation services [email protected]
ESMA Clarifies CASP Agent Restrictions Under MiCA
The European Securities and Markets Authority (ESMA) has confirmed that crypto-asset service providers (CASPs) cannot appoint agents to deliver crypto-asset services on their behalf under the Markets in Crypto-Assets Regulation (MiCA).
Core Highlights:
- No tied agent regime: Unlike MiFID II, MiCA does not allow agents to act on behalf of CASPs by receiving/transmitting orders or providing advice.
- Direct authorisation required: Only authorised CASPs or financial institutions that meet specific notification requirements (Article 60) may offer services in the EU.
- Independent authorisation mandatory: Any third party intending to provide crypto-asset services must obtain its own CASP licence.
This clarification ensures regulatory consistency and prevents unregulated intermediaries in the crypto sector.
ESMA Risk Monitor Highlights Surge in Stablecoin Market and Crypto Trading
The European Securities and Markets Authority (ESMA) has published its latest “TRV Risk Monitor”, outlining key trends and vulnerabilities in the financial sector, focusing strongly on the evolving crypto-asset space.
Key findings:
- Stablecoin Market Growth: Market capitalisation reached €204 billion by December 2024, up 34% since June.
- Tether (USDT) holds the lead with 65% market share.
- USD Coin (USDC) follows at 21%.
- Euro-based stablecoins remain marginal.
- Crypto Market Activity:
- Trading volumes surged by over 200% in November 2024.
- Binance dominates with 39% market share among exchanges.
- Other platforms are also growing due to the broader market rally.
- Tokenisation:
- Still in its early development but gaining momentum.
- Currently, there are no immediate financial stability risks, per the Financial Stability Board.
- Regulatory attention remains crucial as the sector expands.
- DLT Pilot Regulation:
- The EU approved two DLT-based market infrastructures, reinforcing its support for blockchain innovation and financial sector modernisation.
CAMEG: Existing Frameworks Sufficient for Crypto Risk Management
The Crypto-Asset Monitoring Expert Group (CAMEG) reports that current EU regulatory frameworks adequately manage crypto-asset risks.
Key Points:
- Stronger Oversight: Enhanced access to shared crypto datasets improves coordination among EU regulators.
- Data-Driven Supervision: Better data supports analysis of blockchain activity and market trends.
- CAMEG’s Role: Established in 2023 to boost cooperation between the Eurosystem and the European Systemic Risk Board.
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