Overview
CySEC is the Cypriot financial regulator and one of the most used EU entry points for financial and crypto businesses. Since MiCA came into full application on 30 December 2024, crypto-asset service providers in the EU are authorised under MiCA rather than under purely national regimes, and national CASP registrations have been transitioning across.
Why a UAE founder cares
Because MiCA authorisation passports. A CASP authorised in Cyprus can provide services across the European Economic Area without separate authorisation in each member state.
That is the opposite of the GCC position, where every jurisdiction licenses separately and none recognises the others. It is the single strongest argument for a dual UAE and EU structure: the UAE entity serves the Gulf and the rest of the world; the Cypriot entity serves Europe.
What it requires
Authorisation classes tied to the services provided. Own-funds requirements by class. Genuine substance in Cyprus — directors, staff and premises, tested by a regulator that has been criticised in the past for letting substance slide and is not inclined to repeat it. Governance, custody and conduct arrangements to MiCA standards.
What to verify
The transitional arrangements for national CASP registrations moving to MiCA authorisation, and the end date that applies. This is the detail most likely to be out of date in any secondary source, including this one.
How we help
We advise on market access before a sales team is pointed at a country, document the basis on which clients in each market are accepted or refused, and build the controls that make that basis hold. Where a second licence is genuinely needed, we run it.
- 01
Structuring
Activity mapping, regulator selection, group and holding structure.
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- 02
Entity incorporation
Trade name, initial approval, lease, corporate documents.
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- 03
Regulatory initial approval
Permission to incorporate and build. Not permission to operate.
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- 04
Policies and technology build
Rulebook-mapped policies, custody and key management, technology audits.
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- 05
MLRO appointment and goAML registration
Entity and officer registration, sanctions screening, reporting workflow.
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- 06
Bank or EMI onboarding
Frequently the longest single dependency, and outside the regulator control.
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- 07
Full licence
Operational permission granted.
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- 08
Ongoing supervision
Reporting, audits, filings, variation of permission.
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常见问题
Can we serve EU retail clients from Dubai?
Not lawfully as a general proposition. Serving EU clients with crypto-asset services engages MiCA, and MiCA expects authorisation. This is the red flag the jurisdiction engine raises first, because it is the one most often ignored.
Do we need both a UAE and an EU licence?
Only if you want both markets. Many businesses do, because the UAE serves the Gulf and Asia efficiently and the EU is reachable only through an EU authorisation. The two entities should be structured so that neither drags the other into a perimeter it did not intend to enter.
资料来源
- Cyprus Securities and Exchange Commission (CySEC) — current framework and guidance — Position to be confirmed against the regulator's own publications before reliance