Initial situation and challenge
- The shareholders of the first German stablecoin issuer under MiCA decided to establish a joint venture for an e-money institution regulated in Germany. The e-money was to be issued in the form of a MiCAR-regulated e-money token (EMT)
- A designated CEO was appointed to implement the project. There were no other staff members at that time.
- The CEO commissioned FinPlanet as a company builder to develop the product, establish appropriate corporate structures and processes, and, in parallel, prepare a license application in accordance with ZAG, taking into account MiCAR requirements.
- Due to MiCAR not yet having comeinto force, regulatory requirements for EMT issuers, particularly with regard to Level 2 requirements, were still largely unclear
Tasks assumed by FinPlanet
- Establishment and incorporation of the legal entity
- Definition of the target operating model,taking into account any regulatory requirements
- Implementation of the structural and procedural organization, as well as development of the product for go-live
- Preparation of the license application and communication with the supervisory authority
- Conducting a provider selection process
- Ongoing project management and preparation of reports for shareholders
Added value for the client
- Implementation of a regulatory-compliant structural and procedural organization for the live operation of a ZAG-regulated e-money institution that issues an EMT in accordance with MiCAR – the first in Germany
- Preparation of a license application with several hundred pages covering all subject areas
- Obtaining a license as an e-money institution under the ZAG in just 9 months after submitting the license application
