Obtaining an authorization involves a structured two-step process:
Step 1. Preparation of Business-Related Documents: This includes the development of a Business Programme, an assessment of management and HQ shareholders, as well as the compilation of financial information and calculations.
Step 2. Preparation of Regulatory Documents (Policies and Procedures): This encompasses the creation of all required Policies and Procedures in compliance with applicable regulations.
From a practical perspective, the Preparation of Regulatory Document (Step 2) it is expensive and long process. Many entities rely on law firms, therefore the documents lack practical implementation and customization, full compliance with regulatory requirement and thus challenges with supervision authorities come up at later stage.
The following list covers required Policies and Procedures for CASP’s authorization under the Markets in Crypto-Assets (MiCA) Regulation: