Client
A global crypto-asset service provider (CASP) operating across multiple jurisdictions, offering digital asset custody, exchange, and wallet services while handling sensitive customer data and regulated crypto transactions.
Challenge
With the introduction of the EU Markets in Crypto-Assets Regulation (MiCA), the client faced significant regulatory and operational challenges, including:
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Regulatory Readiness & Gap Assessment:
Identifying gaps between existing controls and MiCA regulatory requirements for crypto-asset service providers. -
Governance & Risk Management Alignment:
Establishing formal governance, risk management, and internal control frameworks required under MiCA. -
ICT & Operational Resilience:
Strengthening ICT systems, cybersecurity controls, and operational resilience to meet regulatory expectations. -
Policies, Procedures & Compliance Documentation:
Developing formalized policies for crypto custody, incident management, outsourcing, and risk oversight. -
Regulatory Audit & Supervisory Readiness:
Preparing for regulatory scrutiny from EU competent authorities and ongoing supervisory engagement.
Solution
The crypto-asset firm partnered with COE Security for end-to-end MiCA compliance enablement. Our cybersecurity, regulatory, and governance experts delivered a structured, regulator-aligned approach to ensure full readiness.
Phase 1: MiCA Gap Analysis & Regulatory Readiness
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Conducted a comprehensive MiCA regulatory gap assessment across governance, ICT, cybersecurity, and operational risk.
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Mapped existing controls against MiCA requirements for CASPs.
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Identified deficiencies in governance, ICT risk management, and crypto-asset safeguarding.
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Delivered a tailored MiCA compliance roadmap with prioritized remediation actions.
Phase 2: Governance, Policy & Control Framework Implementation
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Designed and implemented MiCA-aligned governance structures, including:
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Risk management and internal control frameworks
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Compliance and oversight functions
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Developed and formalized MiCA-compliant policies, including:
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Crypto-asset custody and safeguarding
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ICT risk management
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Incident detection and response
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Third-party and outsourcing risk
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Strengthened cybersecurity and ICT controls to meet regulatory resilience expectations.
Phase 3: ICT Risk, Cybersecurity & Operational Resilience
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Implemented enhanced ICT security controls and monitoring capabilities.
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Established operational resilience measures aligned with EU regulatory expectations.
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Conducted control testing and risk assessments to validate compliance.
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Delivered staff training on MiCA governance, ICT risk, and regulatory obligations.
Phase 4: Supervisory & Regulatory Audit Readiness
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Prepared regulatory documentation and compliance evidence for EU competent authorities.
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Supported supervisory readiness for MiCA authorization and ongoing regulatory reviews.
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Provided hands-on support during regulatory interactions and audits.
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Ensured all regulatory evidence aligned with MiCA supervisory expectations.
Results
With COE Security’s regulatory and cybersecurity expertise, the client successfully achieved MiCA compliance readiness, resulting in:
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Regulatory Compliance:
Demonstrated alignment with EU MiCA requirements for crypto-asset service providers. -
Enhanced Cyber & ICT Risk Management:
Strengthened cybersecurity posture and ICT governance. -
Improved Operational Resilience:
Reduced risk of service disruptions and regulatory breaches. -
Regulatory Confidence:
Increased trust with EU regulators and stakeholders. -
Market Credibility:
Positioned as a compliant, trustworthy crypto-asset service provider in the EU market.
Client Testimonial
“COE Security played a critical role in our MiCA compliance journey. Their deep understanding of regulatory requirements, combined with strong cybersecurity and governance expertise, ensured we were fully prepared to meet EU regulatory expectations with confidence.”