MiCA Decoded: Why the Regulator Sees Your Compliance Team as a Single Brain
MiCA Decoded is a 12-article weekly series for News, co-authored by LegalBisons Co-Founding and Managing Directors: Aaron Glauberman, Viktor Juskin and Sabir Alijev. LegalBison advises and FinTech companies on MiCA licensing, CASP and VASP applications, and regulatory structuring across Europe and beyond.The Myth: Outsourcing a Compliance Officer Is Enough When founders begin planning for crypto-assets services providers (CASP) authorization, the conversation almost always arrives at the same moment: “So, do we need to hire a compliance officer?” Sometimes the question comes with a follow-up: “And a Money Laundering Reporting Officer (MLRO)? Is that it?” The answer to both is yes. But treating those two appointments as the finish line is the most common and consequential misreading of what MiCA actually demands from a compliance function. Regulators are not checking whether the org chart has the right job titles. They are assessing whether the management body, as a whole unit, has the knowledge architecture, the structural independence, and the documented operational depth to run a regulated financial institution. A MiCA license is not issued to a person. It is issued to an organism. This distinction sits at the heart of why so many early-stage applications stall or require significant rework before a National Competent Authority (NCA)