Insights · MiCA
CASP perimeter, said plainly
MiCA did not invent crypto. It named services. Custody, trading platforms, exchange, advice, portfolio management — each has a box. A German desk starts with a list of what the client actually does, not with a logo.
We ask for the live flow: who holds keys, who matches orders, who talks to the user, who keeps fiat. If those jobs sit in different companies, the map changes. A white paper that ignores the flow is a brochure.
Hainlex will not write “fully authorised” into a landing page. If a paper exists, it belongs in the Impressum and in Terms, with the legal name that is on the paper — not with the public desk name.
A first reading produces a two-page note: in, out, or not yet knowable, plus the missing contracts.