"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 will grant authorization."
"Members of the management body must possess the appropriate knowledge, skills, and experience both individually and collectively. That single word, collectively, is doing significant regulatory work."
Founders planning for CASP authorization must hire a compliance officer and MLRO, but these roles alone do not fulfill MiCA's requirements. Regulators evaluate the entire management body's knowledge, independence, and operational depth. A MiCA license is granted to an organization, not an individual. Article 68(1) emphasizes that management members must have appropriate knowledge and skills collectively. The EBA and ESMA guidelines detail the necessary professional experience in financial markets regulation and AML/CTF compliance, highlighting the importance of a well-rounded management team.
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