01
European Customers
Continued access to the target European market.
Medici Expert Cases
From a CASP Application to a Swiss SRO Structure
A Czech crypto exchange had already started its CASP application. The licence would have required an operating model the business did not need. We moved the core to a Swiss SRO structure and covered EU services through a white-label arrangement with a licensed CASP. The product stayed intact.
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Case
at a Glance
Client:
Operating crypto exchange / VASP
Situation:
Czech VASP with a team and offices · CASP application in progress
Challenge:
Keep serving European customers without building and running a full CASP
Medici Scope:
Regulatory strategy · Jurisdiction selection · SRO setup · White-label structuring [[confirm]]
Jurisdiction:
Czech Republic → Switzerland · EU
Timeline:
[[Timeline]]*
Outcome:
New regulatory structure · EU customers served through the partner model · Product economics preserved*
Context
An operating business, a new regime, and a licence that did not fit.
The client ran an established VASP in the Czech Republic: a team, offices, customers and a working product.
When MiCA arrived, a CASP application looked like the natural next step, and the process started.
A CASP licence, however, is not only an authorisation. It brings capital requirements, governance, staffing and reporting. Mapped against the client's real activities, much of that infrastructure served no purpose for this business.
Leaving the European market was not an option. The question became which structure fits the business the client actually wants to run.
The Challenge
Change the regulatory route without breaking the commercial model.
01
The Actual Operating Model
A structure matched to the real customer base and business model.
01
The Product Advantage
Fast exchanges, quick withdrawals and competitive swap economics had to survive the restructuring.
From CASP Application to a New Structure
01
Reassess the Route
We treated the existing application as a decision to review, not a commitment to complete.
02
Define the Perimeter
Which regulated activities does the client perform itself, and which require EU authorisation?
03
Set Up in Switzerland
SRO membership under the applicable Swiss framework.*
04
Structure EU Access
A white-label arrangement with a licensed CASP for services requiring EU authorisation.*
05
Operate the Revised Model
European customers keep the same product on a structure that fits.
One operating model. Two regulatory layers.
What Made the Case Difficult
Two regimes, one product, and no gaps between them. In plain terms:
01
SRO
In Switzerland, many financial intermediaries meet their AML obligations by joining a self-regulatory organisation recognised by FINMA. The SRO supervises them on AML matters.
01
White label
The client's product reaches EU customers through the regulatory infrastructure of a partner that holds the relevant licence. The partner remains responsible for the regulated services.
01
Why both
SRO membership does not provide EU passporting rights or CASP authorisation. The Swiss structure covers the client's own operations; EU-regulated services sit with the CASP.
The core task was drawing that line precisely, so that every regulated activity has a clear owner.
Our Approach
We changed the regulatory route, not the business.
01
Review the CASP route.
We started from the client's activities, customer model and operational needs, not from the application already filed.
02
Separate the regulatory functions.
The client's own operating setup on one side; EU-facing regulated services through the CASP on the other.
03
Move the core to Switzerland.
The SRO route matched the activities the client intended to perform itself.*
04
Structure European access.
A white-label arrangement covers the services that require EU authorisation.*
05
Protect the product model.
Speed, withdrawals and swap economics were design requirements from the start.
The Outcome
A new regulatory structure. The same product.
01
Swiss Structure
The business operates on a setup built around the Swiss SRO framework.*
02
European Market Retained
EU-facing services run through the white-label CASP arrangement.*
03
Product Preserved
Speed, swap economics and withdrawals remained intact.
04
No CASP Build-Out
The company no longer carries the cost of infrastructure its model did not require.
[[Medici's specific work and figures]]
*The availability of SRO, white-label or partnership structures depends on the specific activities, customer locations, allocation of regulated functions and applicable law. Swiss SRO membership does not by itself provide EU/EEA passporting rights or CASP authorisation.
Considering Your Own CASP?
First establish whether the business needs one.
01
Which regulated activities will you perform yourself?
Your product, customers and transaction flows define the regulatory perimeter.
01
Which capabilities must remain in-house?
Not every step of the customer journey has to sit in the same entity.
01
Can a licensed partner provide part of the regulated infrastructure?
Depending on the model and the allocation of responsibilities, a partnership or white-label structure may be the more proportionate route.
The objective is not to avoid regulation. It is to build the regulatory structure around how the business actually operates.
Defining Your MiCA Strategy?
If your VASP is moving to MiCA, tell us what the business does, where your customers are and which functions need to stay in-house. We will assess whether your own CASP fits the model, and which alternatives are available.
Discuss Your Case