Infrastructure for MiCA CASPs, Crypto Exchanges, and Brokers

Each product has a regulatory shape it must be built in, and each is already live in the market. Earn: MiCA Article 50 bars paying any holding-linked benefit on e-money token balances, but lending sits outside MiCA scope, so the live structure is a curated vault the client lends into, receiving a vault position and earning what borrowers pay; a MiCA-licensed neobank runs it client-side today, and a systemically important bank group runs the same structure on its own stablecoins. Staking: ESMA Q&A 2067 treats staking-as-a-service as ancillary to custody; the validator operation is rented, and the build is the per-customer reward record a statement and a tax return are made from. Credit: a Lombard loan against pledged crypto, outside MiCA scope under Recital 94, with ESMA confirming a CASP may offer it; collateral is marked continuously and margined at disclosed thresholds, with a margin call before partial liquidation. Cards: spend authorised in real time against the customer's own smart account, with the program never taking custody. Euro balances: a third-party e-money token distributed from a licensed issuer; custody and transfers of EMTs also count as payment services under PSD2, so since the EBA's no-action window closed on 1 March 2026 a non-bank CASP needs a PSP authorisation or partnership for that leg. We build each rail into the venue's existing custody, ledger, and consent flows.

An authorised CASP inherits an operating chain along with the licence: client onboarding and screening, Travel Rule data on every transfer under the recast Transfer of Funds Regulation (applying since 30 December 2024, with no de-minimis threshold on the information duty), record-keeping under Delegated Regulation 2025/1140, continuity arrangements under Delegated Regulation 2025/299, and DORA for ICT resilience. Self-hosted addresses carry their own tests: a EUR 1,000 threshold for assessing control, and EBA guidelines that prescribe five verification methods, with a bare self-declaration not among them.

The difference between a stack that passes examination comfortably and one that consumes the compliance team is architectural: each obligation should produce its own evidence as it runs, so an examination is served from records that already exist. That is a data-engineering problem as much as a legal one, and it is the problem we build for, including for venues absorbing a migrating client book at a multiple of normal onboarding volume after the July 2026 cliff.

We build the venue, the rails, and the evidence chain. For the venue itself, DEX development covers matching, routing, and liquidity engineering, including permissioned, KYC-gated venues. For custody, Safe multisig deployment and Fireblocks integration put client assets under key governance a regulator can trace; we are an official Safe Guardian with $2B+ secured across 120+ networks.

For the compliance chain, compliance integration wires KYC, screening, and Travel Rule flows into the venue's stack. For products, white-label lending powers credit and vault-lending earn, validator infrastructure powers staking, and account abstraction powers card spend from smart accounts. Proof of Reserve attests client balances continuously, smart-contract audit hardens everything that touches client assets, and managed on-chain operations runs the monitoring and on-call after launch.

Each blueprint in our library is an architecture running at a regulated institution today, documented down to the regime that permits it, who operates it, and which layers you own, rent, or have us build. Eight are drawn for CASPs, exchanges, and brokers: