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. 

Be the first to get news from Crystal

Compliance | June 9, 2026

DAC8 CARF reporting compliance for crypto platforms in 2026

A 2026 readiness guide to DAC8 and CARF reporting for VASPs: scope, deadlines, the reportable data set, and the data layer to file on time

Sanctions | June 4, 2026

Crypto sanctions screening: OFAC targets Iran exchanges

OFAC designated Iran's four largest crypto exchanges on June 2, 2026. Here's what VASPs must screen for and why the window to act is now.

Market Analysis / Research | June 3, 2026

The third-largest stablecoin almost never leaves its own system

USDS ranks third by stablecoin supply. Crystal Foresight maps the backing, the transfer volume, and who actually holds the savings vault.