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Payments Insights #5 – When CASPs Overlap PSPs Banking & FinanceFinTech

Payments Insights #5 – When CASPs Overlap PSPs

The EU’s Markets in Crypto-Assets Regulation (MiCA) provides in Article 70(4) that a crypto-asset service provider (CASP) offering payment services related to its crypto activities must either obtain a payment institution authorisation itself or partner with an authorised payment service provider (PSP) under PSD2. This reflects the “dual nature” of certain crypto-assets: notably, MiCA classifies e-money tokens (i.e. stablecoins) as electronic money, meaning they are not only crypto-assets under MiCA but also “funds” under the Second Payment Services Directive (PSD2). In practice, this dual status raised uncertainty about whether CASPs dealing in stablecoins need a separate PSD2 licence in addition…
Katya Tua and Mario Mizzi
4th July 2025
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ICT Aspects of a MiCA Application DORAFinTech

ICT Aspects of a MiCA Application

On the 17th of June 2025, the Malta Financial Services Authority (“MFSA”) published a circular titled ‘Follow-Up Circular to the Industry on the Authorisation Process for MiCA Applicants’. The circular concerns the authorisation process for crypto-asset service providers (CASPs) under Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), as integrated in Maltese law through Chapter 647.  This circular supplements the Authority’s communication of the 10th December 2024 which was explained in a previous legal update. The June 2025 circular introduces two additional annexes that are now required as part of a complete MiCA application file. These are Annex AX05 (Digital…
Mamo TCV Advocates
20th June 2025
Tokenisation of Funds
Fintech Insights #11 –
Tokenising Fund Units FinTechInvestment Services & Funds

Fintech Insights #11 –
Tokenising Fund Units

Malta has uniquely positioned itself at the crossroads of EU legislative initiatives of investment funds and digital assets. The island has steadily built a forward-thinking fintech ecosystem whilst at the same time maintained an investment fund framework which is comparable to those with the EU’s largest jurisdictions by assets-under-management (“AUM”).  This makes Malta the ideal EU jurisdiction to set up a tokenised investment fund. In June 2025, the Malta Financial Services Authority (“MFSA”) published a detailed ‘Position Paper on Tokenisation of Fund Units’ (the “Position Paper”), reflecting Malta’s ongoing pioneering approach to digital finance and asset management. The paper emphasises…
Katya Tua and Mario Mizzi
18th June 2025
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MFSA Amends MiCA Rulebook FinTech

MFSA Amends MiCA Rulebook

On the 16th of June 2025, the Malta Financial Services Authority (“MFSA”) published a circular containing an updated version of the Markets in Crypto-Assets (MiCA) Rulebook, together with targeted amendments to Chapter 3 of the Financial Institutions Rulebook (FIR/03). These updates implement the recently issued Level 2 and Level 3 EU measures under the MiCA framework and clarify the notification procedures for crypto-asset market participants. The updated provisions are effective immediately as of its publication. The updates to the MiCA rulebook were carried out to ensure alignment with recently published guidelines by the European Supervisory Authorities (“ESAs”), and are as…
Mamo TCV Advocates
17th June 2025
High rise in Malta
Fintech Insights #10 –
Raising Funds Through Tokenisation FinTech

Fintech Insights #10 –
Raising Funds Through Tokenisation

The EU’s process towards further harmonisation of its Capital Markets Union (“CMU”) provides a timely context for the implementation of tokenisation. The CMU aims to create a single, integrated financial market across the EU, fostering cross-border investments, mobilising citizens’ personal savings and reducing the reliance on bank-driven financing. The implementation of tokenisation within capital markets can help achieve these objectives by enabling frictionless trading and unlocking access to new pools of capital whilst increasing liquidity. As discussed in the previous insight on tokenisation in Malta, tokenisation reimagines asset representation by embedding ownership and legal rights into programmable tokens recorded on…
Mario Mizzi
17th April 2025
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MFSA Consolidates Maltese CASP Supervision FinTech

MFSA Consolidates Maltese CASP Supervision

On the 4th of April 2025, the Malta Financial Services Authority (“MFSA”) published a circular addressed to all crypto-asset service providers (“CASPs”) licensed under the Markets in Crypto-Assets Act, Chapter 647 of the Laws of Malta, which integrates the EU’s Markets in Crypto-Assets Regulation (“MiCAR”). The circular informs CASP licence-holders (“LH”) of the publication of the Crypto-Asset Service Provider Return (“CASP Return”). The CASP Return forms part of the MFSA’s efforts to build a consistent and transparent regulatory framework for CASPs in Malta. Through the introduction of formalised reporting obligations, the Authority will support greater regulatory oversight and contribute to…
Mamo TCV Advocates
8th April 2025