Beware of scammers impersonating Crystal Intelligence

MiCAR insights | October 23, 2024

MiCAR Vaduz Roundtable: EU Crypto Compliance Challenges

by Crystal Marketing Team

The Vaduz MiCAR Roundtable, hosted at the University of Liechtenstein on October 4, 2024, delved into critical aspects of implementing the EU’s Markets in Crypto-Assets Regulation (MiCAR). Experts discussed challenges and proposed solutions related to compliance, fund management, and cross-border services. 

Own Fund Requirements

Dr. Christian Steiner highlighted MiCAR’s rigid framework for Crypto-Asset Service Providers (CASPs), requiring fixed overhead-based calculations that disproportionately burden larger firms. Participants proposed integrating risk-sensitive factors and allowing the use of AT1 and Tier 2 instruments to provide flexibility. Excluding non-regulated services from overhead calculations was suggested to avoid inflated requirements for diverse business models.   

Gas Fee Stations and Fund Segregation

Nina Gartmann addressed the challenges posed by Art. 75 MiCAR, which mandates strict segregation of client and provider assets. The discussion explored solutions like enhanced ledger-level segregation, clear contractual definitions of gas fees as client funds, and outsourcing gas fee management to third parties. These approaches aim to align with MiCAR’s requirements while minimizing operational complexity. 

CASP Passporting and NCA Intervention

Alireza Siadat analyzed the relationship between cross-border service provision under Art. 65 and product intervention under Art. 105. Concerns about host National Competent Authorities (NCAs) undermining passporting through regulatory barriers were raised. Participants emphasized the importance of limiting interventions to specific risks and proposed creating a whistleblowing mechanism for CASPs facing unfair treatment.

Outsourcing to Non-EU/EEA Providers

Dr. Thomas Nägele highlighted MiCAR’s restriction on outsourcing key services to non-EU/EEA entities, posing challenges for companies relying on traditional outsourcing hubs like Switzerland. Suggestions included developing a “safe harbor” provision and exploring hybrid models to maintain compliance while leveraging third-country services. 

Conclusion

The Vaduz MiCAR Roundtable underscored the need for regulatory adjustments to address the unique challenges of the crypto industry. Tailored solutions, such as flexible own fund frameworks, clear segregation standards, and harmonized cross-border practices, are essential. By refining these regulations, MiCAR can support innovation while maintaining robust safeguards, ensuring a balanced and competitive EU crypto market. 

Agentic Payments | August 27, 2026

Agentic payments need agentic evidence

Agents are starting to pay each other at machine speed. Your evidence has to move just as fast.

Thought Leadership | August 21, 2026

What the A7A5 stablecoin did after Grinex collapsed

A7A5’s supply never left after Grinex collapsed. What dormancy means for sanctions screening and AML monitoring.

Decision Intelligence | August 20, 2026

What is decision intelligence for digital assets?

This guide introduces decision intelligence for digital assets: why the market needs a new category, and how it turns on-chain and off-chain.