EN | A Year with MiCA: What’s Working, What’s Not | MERGE Madrid 2025

Thank you so much, Musha. Gracias. Yes, we're very happy to be here talking about uh the marketing crypto assets regulation uh which you might have all heard about already is the major regulatory framework being introduced by the European Union and that is finally providing regulatory certainty and clear rules for the crypto asset industry. And we're basically one year into Mika now. And we're very happy to be talking about what is working, what is not working, what might be some areas that need to be revised and uh maybe answer uh some questions from the audience.

We also would love to hear from you maybe at the end of our initial conversation. So if you have your questions, please uh don't be shy and ask them so that we can actually have a bit of a interesting conversation. And that's actually what we're going to try to do today. have a a natural debate, a natural conversation, not too structured. So, I like to have my panelists and speakers go one after the other talking and potentially disagreeing with each other, which is always uh always makes it for a nice panel.

So, once again, my name is Tomas Astati. I'm the policy director at Blockchain for Europe. Blockchain for Europe is a trade association. So, representing the blockchain industry, the crypto companies in Brussels with the European policy makers. So Mek has been obviously our bread and butter for uh the last few years and I'm very actually honored to be working with a lot of these people here, a lot of these entities that are members of our associations and we're doing some very interesting uh work together in Brussels and it's great to have them here today on stage.

But without further ado, we get started. Maybe a first quick round of introductions from our panelists. they can tell you a bit more who they are, where they're working, what their entities focus on, and then we can start talking about Mika. So, Vbec, you want to get it started?

Sure. Thanks, Tomaso. So, first of all, it's an honor to be here, and uh thank you for having us. It's always good to be having you as a moderator because you are assured that it's going to be a good conversation. And again, uh I'm from uh BSV Association.

Those that don't know us, uh we are a layer 1 blockchain. Um, I represent the as head of the business and yeah, it's a pleasure to be here and uh, I'll pass it on to you.

Hi everyone, I'm Luthia Suarez. I'm the head of compliance for crypto and digital assets initiatives and I cover globally the Santander Group.

Hi everyone, I'm Brian Gatan. I'm the MD for Europe operations for Kraken. Um, I'm based in Ireland. um for those of you and I'm aware that this event has a kind of nexus of um crypto ogs and uh more new newer entrance into the space and and and traden is one of the world's oldest and most performant and most secure um crypto exchanges. We've been around for many many years, 14 plus years and we have a long history in in Europe particularly of being a market leader in in euro liquidity and easy uh payment rails.

uh for our clients across Europe and particularly in Spain I guess as well. We've um we've been registered with the Bank of Spain since 2023 and uh investing in the market here locally and um more recently this summer we've uh passported our our Mika CASP license which I guess is what the panel is about into into Spain and are offering our diverse uh and extensive product suite into into Spanish clients um you know through that Anthony. So yeah, excited to be here to talk about what is and what's not working with MA.

Thank you, Oliver.

Yeah. Hi guys, my name is Oliver Star. Um I run Coin Europe as their CEO here. Um we are running for the Mic license in out of Austria, Vienna. So we have a headquarters there.

And um yeah before that I used to be um qualified lawyer uh which comes in handy when it comes to Mika and all the other um uh regulatory requirements we need to fulfill because it's not only about Mika there are a lot of other uh topics we need to cover with uh we also have a quite decent product suite which is not only covered by Mika but also MITI and and and other license regimes. So um yeah happy to be here and looking forward to a nice discussion with you guys. Thank you. And Christian,

thank you. Uh it's a pleasure to be here. Thank you for uh having me. Um Christian Menda, um director for chain analysis for Spain, Portugal, and Pandora. And well, pretty much chain analysis is the uh leader in analytics uh regarding uh blockchain.

We work alongside uh law enforcement, regulators, uh exchanges, uh Trafi and every single company that plays something in in the ecosystem. Uh and yeah, very excited to be here.

Thank you.

Perfect. Thank you. Uh I have to say this is pretty a pretty stellar panel, right? So we have uh some uh some big names in terms of entities, some very important uh roles and everything. But it's what I think it's very interesting is that we have different type of entities right we have the biggest change is the trading platforms uh that maybe everybody in the retail space will know of course but then we also have the blockchain analytics companies we have the let's say more traditional financial institutions that are looking at Mika looking at the blockchain space with a lot more of interest into developing and some other type of different entities that are you know looking at Mika of course looking at the blockchain um and web3 space but maybe not in the same exact way as a centralized provider might do.

But let's get started. Let's talk about Mika. We you probably all heard again what Mika is. I don't think we need to do much of an introduction. Uh but let's hear from our panelists what do you think about MA?

What what's your views? How does MA actually impacted your business if it has? And uh and yeah, so let's start from there and then we can see what's good and what's not. Adam,

do you want me to take that?

You go ahead v if you want to get started.

Uh the BSV association, we kind of welcome any kind of a compliance or regulatory framework. That makes sense. Uh having said that, like one of the things that we've actually going to be announcing quite soon and I think this is a great platform to do so as well is we've uh done our Mika white paper as well. uh we just need to go through the submission process of all of this and again the idea behind that is to create a bit of trust and I think this kind of offers that framework and steps like builds that kind of stepping stone means but again like everything it's in its early stages and I think there's quite a lot to be done in that aspect but again time will tell and uh we'll see how that goes but from our side we think it's it shows kind of clarity and again We want uh developers, institutions, enterprises to adopt uh the technology and this kind of builds that foundation for it.

Great. Lucia, you want to go next?

Yes. So, we can look it from micro and macro perspective. So, let's go.

Let's take us on this journey.

Uh Sand there. Well, we are regulated entities. So for us it opens the door to offer another type of asset class which is really really nice. So basically you already have the client, you already have the experience and now you can offer something that is interesting for these clients from different points of view. So you can have uh portfolio diversification etc.

So it's really interesting for us as you know as a regulated entity we cannot offer nothing that is not regulated. So that's the benefit for us. If we look at the macro space uh for me the big win is that it brings um kind of customer protection. So the thing is in the past uh there has always been this kind of discussion that crypto is very very dangerous that crypto is not well explained that there there is if something goes wrong there is nobody to call uh no no um attention to the client and Micah has brought this kind of security in that part that is really important uh so that we have mass adoption Um, let's look at Spain. Um, the average of the people that have the money are people above 40 or 30 years old.

So, you need to bring them security so that they can get into this space. So, that's one of the big impacts for me for the society of Micah.

Thank you so much. So, we already heard some interesting perspectives, right? uh and especially when you look at a traditional financial player like uh group of Santandere that was already regulated for providing um obviously financial services but now thanks to the Mika framework they also had the opportunity to provide a different set of assets uh different type of services to their users which I'm sure are becoming more and more interested in these new products uh but then probably when we go to the our next panelist M is really more even more fundamental right and it gave them the legitimacy to do what they're doing, but also maybe you can already start telling us a bit about the licensing process and challenges. I think it could be interesting.

Yeah, sure. So, yeah, I mean like Mika, you know, is something that Kraken had advocated for many many years and both both of my panelists who've already spoken talked about regulatory certainty and and and things like that. So we Kraken has a long history of working closely with regulators in Europe and in the c in in Ireland with the central bank of Ireland where which is our primary regatory hub. So we have we had that certainty in you know across our product suite with the exception I guess of of many of the main crypto offerings. So we had an EMI going back a number of years which provided you know a clear rulebook for how we handle fiat on-ramp offramp safeguarding client funds in in the kind of fiat space to help bridge into into that that uh crypto economy.

Um we had a we had a a myth 2 license entity out of Cyprus to offer you know financial instruments under under under me and you know this was the kind of missing piece which we which we have now. Um so it provides that kind of clear rude book rule rule book codifies practices that you know Kraken had advocated for and had you know in many so now we have a level playing field the consumer across Europe knows what they're getting from a from an authorized CASP and knows what kind of consumer protective measures are in place whether it's how we handle custody funds or market abuse market surveillance um and disclosures things like that white papers which uh which was mentioned there. You can find hundreds we have hundreds of digital assets h offered to our clients and you can find hundreds of them on our website and they've been submitted to an NCA and they've been put on the ESMA register. So like the client, the consumer knows what they're getting, right? So it's a career roadmap.

But what that allows Kraken to do who obviously have been in this space for a long long time. It really allows us to invest in accelerating our roadmap of you know innovative products for for clients in Europe that certainty. So look at what and anyone who's followed closely over the last year will have really noticed our product velocity you know can you know really really kind of picking up and like if we think think of examples in Europe we have a what's called a Kraken embed product which allows banks um you know to banks or other fintexs that don't offer crypto to seamlessly integrate with our backend via an API and leverage our technology and offer it to their clients. And I guess the biggest and best example of that is Bunk um which is a a Dutch NEO bank and has many many clients and is now offering our our some of our crypto services to their Dutch clients using our technology in a kind of seamless way. So Luchia if if you want me to connect uh you with um our bisdev guys.

It was actually Victor who was on the panel just before me. Um we can we can make those connections. you can you can you know I'm Santandere have many many clients across Europe and beyond so and Spain so it' be great to get that offering via partnership so we'll see about that but then another example of of of a an innovative product that we're offering under our Mika framework is our bundles product which is for the consumer who you know wants to kind of set and forget appropriate with their risk levels and suitability for the product they can go and choose to you know invest in a in a certain basket of of cryptos and then it's you know associated and linked to their risk level and risk tolerance and then you know it's rebalanced monthly they don't have to think about it. So that's like a real kind of innovative step forward and albeit not under the the under the the mika framework you know recently we've launched XOX which is our version of you know tok to tokenized um equities and that's offered out of our our entity in Cypress. So like you know that like regulation maybe doesn't you know attract many people and find it find it that interesting but that that it is underpinning us allowing us or Kraken being able to offer these innovative products to the market in in in Europe and Spain particularly.

So um yeah it's I get it excited about it at least anyway. Yeah, there's not that many people like us probably that get excited about regulation in the crypto industry. But you know, the more you understand, the more you read, the more I can promise you that it is exciting at least in the intentions, right? And I think we're also going to get towards these points, the intention of the European Union in Brussels, of the European Commission and so on of providing all of this regulatory certainty for the industry was very noble, right? And I think uh as I think Brian was also saying this regulatory framework was also meant to attract businesses, attract companies, attract uh talent and developers to finally build in Europe and uh you know take a lead in this so-called web three race.

Um but you know let's hear whether we're really going in that direction. And I don't know Ollie if you already want to share some thoughts on your experience uh with Mika with the licensing process but if you already want to mention anything that you think might not be working as well in the Mika framework I think our audience would love that.

Yeah happy to do so. So uh you see the difference between this nice guy Brian and myself he already received uh all his licenses and they can talk a lot a lot about products. You know we still running for the license and getting it soon. um hopefully um as I will not talk too much about products and offerings. However, uh this is exactly where what Mika is here for as well and Mi and all the other u um um regulations but um what we need to do and maybe I put this discussion in a little bit uh different um um direction.

Mik is nice. Mik is here to build trust and trust is the foundation we all build on to get a lot of customers hopefully to serve a lot of customers in a very compliant and decent way. So it's the baseline. However, Mika is not Mika unfortunately. Um I'm I'm in this game since a long time already and and I was already advising even uh a lot of people in Brussels back in the days when I said guys if you want to do Mika and if you want to do regulate crypto itself you need to have this level playing field which we are used to in trade since many years with me with EMIs with other stuff with banking regulations but if you're not able to establish this level playing field we're going to have a hard time all of us especially the huge huge uh uh uh players in the world like man Khan also has more than 40 million customers uh uh globally and also quite a bunch of in Europe already but if there are NCAs for example so regulators that um interpret Mika in a different way like for example the Austrian regulator which is a very knowledgeable and and and and good regulator strict but but they understand our products so to say you know what we are doing what we are offering But if this is not the same everywhere in Europe, um we're going to have a hard life because I need to tell my guys um um why we do all that stuff where we'll have already 25 people on the ground, why we have so much cost and then somebody comes and says, "Oh, we do it the easy way and we do for example um mirroring our global order book because we for example uh are running a broker in Europe.

So not an B2B exchange but a broker. So we have a lot of different liquidity providers and you get always best execution on our platform. However, if this is not working um we're going to have a hard life and this is why some of you maybe have um also seen that our regulator together with the France uh French ones and the Italian ones were even writing a letter together to inform the market. Um and it was not too much to the market but to the other uh regulators maybe um directed that they please should come together and align on what they understand with Miker and was not and there are still a lot of topics within Mika that are not 100% sure how to deal with or not you know and um at the other hand and I needed sorry for speaking so long but another topic having a bank here on on on the on the panel so in in at least in Austria, you know, um we have the same regulator, we have even the same auditors at the end of the day. We have the same rules that we need to apply to.

Um but it's impossible still impossible as a a crypto broker or exchange to get a bank account in Austria, you know. Um there are banks in Europe, neo banks model or less that are more open to that. But even our regulator is writing letters to the banks and say guys that cannot be that our our uh regulated entities you know under Mika are not getting bank accounts with you guys even do they apply with the same uh rules. So there's still room for improvement. Yeah though Mika is in place already.

Um and they're really looking forward how this is going to develop to develop in next couple of months.

Thank you. I think we already are hearing a couple of uh potential problems, potential issues, concerns. There has been some talks about um you know the passporting of the license, what NCA's national complent authorities are doing, the different approaches. So I think we're going to get into all of that uh and have a bit more of an open debate nets. But to finish off this round, I think it's also interesting to hear the perspective of Christian and chain anal chain analysis, right?

at analysis they don't really have the same type of need or expectation from the Miraa framework. It's not the same type of platform exchange facing consumers and so on. But I think they also have a very interesting perspective especially because of the data right data can tell you an important story and I think Christian can tell us a bit more about uh about what Mika is when you look at the data.

Thank you. Thank you. Yes. I mean if you look at uh the entrance of Micah Mika uh in the in the market what we've seen is uh first of all of course the entrance of uh the what we call the trap fivey traditional finance players uh that u has uh raised a demand on our products on those type of clients because we previously didn't have that demand uh and you know through that uh and what we're doing is working together with the supervisory authorities uh in Spain and across Europe to you know provide them with uh trainings programs uh so they can grab all the information that datadriven supervisory in real time is much more efficient than uh you know the traditional uh reporting that comes you know every six or nine months. So uh going to your point for example uh if there may be discrepancies between jurisdictions right if you are applying datadriven decisions that disappears right so when you approaching a specific entity to do an assessment you need to do the assessment.

If you use the tools, the appropriate tools that has the right precision of data, then you can make uh you know a good assessment of that particular entity or asset itself. So talking about assets right we also see a big shift right uh uh Micah has came in and then uh we now see a market for euro stable coins uh and you know if we look at Euro C is the uh most uh rapid growing uh stable coin across Europe and u above 2700% between January and and now So uh that that's you know that's what you can see in the data right when you when you have an an understanding. So so we see new players we see the the new market for stable coins in Euro growing fast and and and yeah I mean if we compare that for example with USC uh is only growing 86% rate right so you know different comparation in that sense

maybe I jump in here because this is this is very important for us as well um like companies like Chanelysis and they are also here to to build trust and um the last couple of years um for example even our regulator they were always telling everybody you know crypto is only here for scammers and for fraudsters and for nothing else you know so don't deal with crypto at all but analysis and their data they showed that it's not it's not used that more uh uh that much anymore for this kind of uh uh things you know for the for the illegal stuff so it's what is it nowadays 1% 2% something less than it's really it's it's it's nothing I mean cash is is is used for money laundered much more than than than anything else you know but that we need to to shift this perception you know and chalice is very much helping us as well to gain this trust and say guy we we have decent assets we have good assets good asset classes um and you can trade in a secure and and safe manner on on on our platforms also based on on their data at the end of the day.

People should read the book Tracers in the Dark, by the way, because the the founder of CH analysis is is heavily mentioned throughout that and it's really really kind of goes deep on on what Oliver is kind of talking about there. Like really the the maybe to the to the person in the street that isn't that familiar with crypto, that perception is still there, but you know, us maybe everybody on this stage knows that's not the reality. But that's the kind of challenge for the industry to like you know educate and whether it's regulators um or just everybody in the market and as these trady players come in they will naturally obviously seek to understand that. So um yeah I couldn't I I just want to echo everything Oliver is saying there. I mean I mean and even in in trade fire you would not have this kind of tools like chalysis where you can track everything you know I mean you can every coin you mint or whatever you know you can drag until the beginning and you can immediately um um flag it if it's used for illicit uh uh stuff for example you know this is not in trade file

on that one I always put the same example so in the traditional space you would never know that an ano has been used by an arco like 10 hops away.

Yeah.

With blockchain analytics tool, you can know that a bitcoin has been used by somebody with mark with high risk 10 hops or more ago. And that opens new questions like in the past you can only see your counterparty. So you you care about the risk of your counterparty basically. But now how do you evaluate things that go far beyond that and what do you do with that information which is the new question?

Good question. Yes.

Yeah. Yeah.

It's a management decision you know. So

you can do it you know um

definitely. Yes. An additional angle that Mike also introduces here is the the cyber security spec right. So um that also give us a a a base ground on what kind of uh uh security needs to have this these players are in the market to avoid cases like for example by bit right uh we heard about this 1500 uh millions hack uh that happened and and I think that also is going to the point that Lucia mentioned about protection for the consumer. I mean you placing your money in a in a platform that you're trusting that you having the the right uh you know uh measures man etc to to take care of the the the security and that that's another angle interesting

oh sorry to jump in but really I love this I mean I'm not with bit but you you need to to say that this case was I mean massive

on the one hand I said but at the other side no customer was hurt at all and it was solved within 24 hours more or less. If you go back for example to tradefy, I used to be there. So um um back 20 2008 2009 when we had Leman and all that stuff. I mean it shook the world for a couple of years and we still see the consequences of that now. Um and Leman failed but by still here and is more profitable than ever maybe.

So what I saw there is for the banks the consumer needed to pay that they survived. crypto does it on their own and is still here, you know, and this is a very this this this kind of community, you know, and and how everybody like us as well, I don't know about Kraken, but helped each other to to stabilize the system and to to make the system more more uh uh sustainable. It was really interesting to me as well to to see this.

Yeah. But don't you feel that many of the jurisdictions are not really talking to each other and that in order to harmonize this framework?

Yeah. means that's important right now and I don't see that happening and that's kind of creating a bit of friction in some areas. So you know

definitely

so I think if we get to that point and we kind of like fix that that actually could be a very good potential means I just see that everyone has similar ideas but they don't get to talk to each other which is the important part or agree to a point. Yeah, I think we're touching again upon a few interesting points and keywords, right? We talked about trust uh in the system, in the community. we talk about education and I think education really is the the most important element in everything that we're doing in the work that we do in Brussels but also in a lot of the work that for example uh they are doing as well in terms of educating their users educating the communities educating the policy makers that are taking these decisions and that's really I can tell you it's not an easy job uh but uh but I we're getting also again to some of the issues some of the problems right I think Vivbec just mentioned now there is a risk still of fragmentation, right? There is a risk of differences in the way that authorities are approaching the rules.

Even though there is one set of rules and in theory is rather like relatively clear. I'm not going to say it's perfectly clear, but it's relatively clear text. There are still a few open questions but at the same time now the rules are effective but at the same and and they were aiming to harmonize right regulatory approaches across the EU 27 member states but are we there yet or are we seeing some issues are we seeing some concerns and this is again now it's an open question to anybody anybody that wants to jump in talk a bit about passporting concerns let's let's do it like this First, we talked about level playing field. Level playing field within the European Union. And then we should also probably talk about the level playing field globally speaking.

So, who wants to take this first?

Yeah. Well, I mean, I think you kind of touched on it there, Tomaso, as well. So, the level one text is a level playing field and is mostly clear. Well, and it's not even a long document, right? I mean, and boring people like me read this kind of stuff, right,

before before going to sleep.

Yeah. But like compared to other directives and regulations and regulatory technical standards and so on and you know that I've been looking at for 15 20 years like it's it's it's in simple plain language mostly and you can read it if you can read um we're a year in um we're just over a year if you take it from this kind of stable coin start and you know for CASPs we're less than a year in most most of the countries are still in their transition period. Yes, there has been some uh initial teething problems where there you know there's been areas of fragmentation. Um, but like the focus right now really really should be on implementing the level one text as intended and like I think there's an onus on whatever NCA it is in Europe or and ESMA and so on and so forth to like make sure that as we go through this transition period that that level one text is implemented as as intended and then we get to kind of you know harmonization of supervision by whatever means um that that that occurs. But like so like the those clear rules for everyone across the EU 27 plus three for EA um are like applied the same way and like we we we have an opportunity to do that right so like ma was gamechanging from the fact that like think back to the you know the depths of co when this was being crafted like it was just it was you know for me who'd been working in tradi and then moved into crypto like the thought of a a panu new single regulation for crypto was just kind of fanciful really.

So like Europe has Europe has led the way from that point. Now there's an onus on CASPs tradi players um people come seeking to come into the space to work with NCAs to work with asthma and asthma can produce more guidance or you know there can be level two level three regulation to clarify things and so on and so forth uh to implement this rule book that we've been given. So I think we have an opportunity and I think we can do it and it's still like we're I would say we're still in that transition phase and many players are not yet authorized and you know so we're operating under vast regime so um yes there's been some some teething issues but I think we can get there.

Does everybody agree with this or are you is anybody more concerned about the state of the situation? Well, yeah. I mean, from from us in chain analysis is, you know, we we advocate for a real time data driven supervisory approach, which means if you if you follow that path, uh, you know, not because a a company comes from, you know, a given country, uh, you know, you have to make a, uh, pre, let's say, preit, uh, or or preconcepts of how they should be in behave. behaving you go through the data you can understand exactly what they do and then you can you can add to right so those that's basically u how we advocates uh supervisory authorities and regulators in Spain across Europe to to act on right of course that requires some uh training programs that requires education that requires uh the the appropriate tools as well of course with the rise precision right because for us uh you know the precision is is quite important right is um as I said you know we work with law enforcement, of course, they use that for a different purpose. But if you are a supervisory authority, right, at some point you may want or you may have a need to emit a a fine to someone, right?

Before you do that, you have to make sure that you are not looking at false positive uh that you know u perhaps that entity that you're looking at is getting um data that is linking them to terrorist finance which is not true or cam or any other thing which is not true and you're creating a perception of that entity that is wrong or that asset right so I think precision is key and uh we recently have an study that was published uh an independent study where uh that independent study showed that the data that we provide in in chain analysis has less than 0.15% uh of ratio of false positive. So we're pretty proud about the data we provided. It take us a lot of work in a day-to-day basis but uh that provides the security that the industry needs to operate safely.

Indeed.

Maybe I jump on uh um Brian's speech as well. So I I agree with the level one text but when it comes to details there's still a lot of questions uh to to be answered. I don't know for example when it comes to white papers we need to assess all these white papers that we list the tokens for. Um and nowadays you know not all the projects for sure have their white papers. BB for sure is a very good example that that do so because you need to every project needs to um issue their white papers also with either an MCA or or or ESMA directly.

One of the fun factors I see from a practical point of view, you know, ESMA still doesn't publish uh all the the the white papers that are already approved in a proper way. You will not find it. It's a CSV file. You need to search for 10 minutes to even find it, you know. So I don't I don't know.

register is also a CSV file as well. It's a nightmare.

So, and when it comes to white papers, Kraken is a very good example. You you do some white papers on your own because not every project has a white paper. So, but what comes if now me as Kcoin or I don't know, Binance, whoever is also putting the the white papers in place and if only a single, you know, clause in these white papers is different, what what counts then at the end of the day, you know. So, there are still a lot of things market surveillance, I don't know. I mean uh insider trading that the two of us you know we would need to uh inform every trade even maybe before we do it I mean I'm in this space in 10 years I I deal regularly that's the like this you know it's it's it's it's really insane still

I agree that the devil is in the details

yeah yeah

and basically what you are mentioning about material nonpublic information so what is material nonpublic information in the crypto space we were discussing about this two days ago at the dart the meeting.

So what do you consider MNPI in the crypto space? When do you consider the information has turned into public?

Yes. For example. Yes.

That's the key. It's a good question.

Yeah. Yeah. And basically you need to have a clear picture on that to be able to know if you comply with Micah in the in the material on public information part or not. Um so there are lots of open elements and open questions

but nobody can answer. So even our NCA they are very knowledgeable but they also say we need to align with Esma or who anybody else because they don't know you know yet but still we we need to already well if it's published in the blockchain is it considered that it got public or not? Can anybody read and understand what has been published in the blockchain or not? So many many open questions just on this piece. So imagine all the others and for me another interesting part has been h in this experience because in our case we got the authorization into countries.

Uh for me a very interesting point has been the combination of micica with DORA with digital operational residence act.

Guys I knew

no don't talk about Dora. I didn't.

So, so it's not just it's not just M

raising the bar.

It's what came together with Micah that nobody was talking about. And all of a sudden, especially you guys, I remember like having discussions and asking and what are you doing about Dora? And the people were saying Dora what's that? So, so yeah very interesting experience especially in the concept of what is outsourcing in your target operating models who has to approve that critical outsourcing that may not be your core regulator for Micah and then it opens two ways for for approvals. So

yeah,

the complexity

complexity

but the interesting thing with that is I and I need to admit I love Dora because it no one you know other brackets

strong words

yes but but but it it it it gives at least for me you know I'm CEO and lawyer and stuff but it gives clarity you know you need to go in the very very very detail at the end of the day you need to really understand your system and what do you outsource and what not and who are Bruce and what not. I need to know everything, you know. H this is quite hard for a global player like like like KCON because they never did this exercise before. For sure not. Even if you have a maybe one of the securest uh uh platforms in in in the world, but nobody was thinking from that angle, you know, to approach that

that level of details and and and this is very interesting and the fact that we all need to do that and you as a banker, you also need to do that um is is is a good thing at the end of the day.

The level playing field we were talking about earlier, right? Uh so I mean again you're probably getting more questions and answers from this panel but that's usually what happens when we talk about Mika right because there is still a few questions there is still a few aspects that no one just has the you know the perfect answer to right and this also comes because as you can hear the complexity of the interplay between different pieces of regulation pre-existing pieces of regulation new pieces of regulation and legislation that was developed with the crypto industry in behind or others that were not right that were pre-existing. For example, when we look at the payment services directive and the payment services rules and how that interacts with Nika when it comes to stable coins and so on. So, we could throw a lot more topics here. I don't know if anybody wants to point to one that you think it's uh interesting or concerning or indeed as we we were touching upon before Nika in the end was also the attempt of the European Union to take a bit of a lead on the global stage right and we're talking about the global market of course crypto is a global market boundaries and and and um you know territories don't really matter that much in the crypto space but of course the regulation of this industry the regulation of the service providers is something that is done by jurisdiction.

So maybe let to give a bit of a an assessment of how do you all think the European Union is moving in that direction try to take this leads also when at the times when there was no regulatory clarity in the United States and this was also been uh perceived as a as a great advantage for the European Union but do we still have that advantage or do you think that things are changing?

Open question. Well, probably um I I you know I I think that this uh Mika Micah uh has given this this this is great opportunity for uh growing this ecosystem uh here and provide those bases that are required uh to protect consumer uh and allow you know traffic to join the ecosystem all that right uh having that in mind we also have to think about what is the global uh spec right uh I don't think we want to end up here in Europe as the isolated island uh of you know crypto regulator which is not in sync with the rest of the world. So I think there's a lot of work that needs to be done at the European level to make sure that uh we align also as well with the US and we align also as well with APAC and in a way that at the end of the day we we have a some somehow harmonized uh uh yeah framework that allows this this uh uh protection to be global, right? It would be of course maybe slightly different in some jurisdictions but you know if you if we can get that to operate then uh I think that would be a great advantage for Europe.

So I I would just I mean and I know we've seen some media reports about you know the potential of opening back up ma you know at the at the parliament level or a mika 2.0 or whatever you want to call it. Um, I would definitely kind of caution against that right now because we're still in a transition period. You talked about datadriven decision-m like we need hard data uh to review and like the the time is probably not now because we you know because the market is still developing and players are being authorized. Um it's it's amazing that Europe led the way and you know in many ways Mika was a very forwardthinking regulation in that it didn't look to stifle innovation through de regulating explicitly excluded DeFi I guess is probably the best way to think about it and now wow we've had the genius act in the US again unthinkable a few years ago there's a market structure bill hopefully coming in the US we know the UK are bringing something forward so like when we have this data from the implement mentation of Mika and we see what other jurisdictions do then maybe we can look at Mika and see what needs to be changed to ensure that there is harmonization across the world because crypto crypto by its nature is is is borderless right so you know we I think we risk fragmentation by opening it up now um when we have a chance to kind of look at see how the market develops and and and see what see what see see what's done in the other G20 you know jurisdictions particularly

thank you for saying that Brian And maybe louder for the people in the back that are listening from the European Parliament. Do not reopen Mika now. We have We need the time. We need the time. This industry needs the time to actually implement the rules, but also the authorities need the time to actually know how to supervise, implement, and enforce the rules, right?

So, I think that's a good message uh to bring us to the closing of our panel. I hope we can still take a few minutes before sending you all off to lunch. uh but maybe actually it's a good time to see if there is any questions in the audience for any of our panelists. If any anything in our discussion generated any curiosity, please don't be shy. If you want to ask anything about Mika 2, about stable coins, about global convergence, all of these topics or any other challenges that we've been discussing on stage, I do not really see much from here because of the lights.

But uh if someone does want to speak, just be very vocal about it maybe. Yes. No. Great. Well, then we can continue a few more minutes as until they kick us out on the stage.

But maybe for last few thoughts from our panelist uh you know what what do you take from from this conversation? What do you think is the the most interesting point that you wanted to our audience actually to to keep in mind? So for me like in this panel has been very refreshing to see like you know from the data side from the banking side from the exchanges side that we are kind of all aligned in the same kind of a thought process specifically like again I get they keep on telling me this at work baby steps we need to follow those and like implement those be secure about what we want to actually achieve and then as you mentioned before 2.0 zero is too early stages to actually going forward for that but we need to start thinking about it we need to start having those conversations as well so I think it's a bit of um mixed bag in in reality and again talk talking about like uh doing the white paper from our experience we didn't have any knowledge or understanding so we had to seek external help to help us like build this so that we can actually do it appropriately because we didn't want to fall under the same issues that others do as well and then go through the whole process which is lengthy as well, costly and lengthy but we do find that there are not that many people out there that really understand things. So it's very refreshing to see when you see one or two companies that actually help you.

Some of them are in the stage around here. So it's good but again we need more education around all of this in order for the adoption to actually happen which is kind of like the motto that we go with. So anyway, that's my

quick one because I'm seeing like we are out of time.

Basically, Micah has been a learning curve for all of us public and private sector. I think uh but it is true that now we have uh kind of an element of global competition.

H genius is coming. Erh, Genius opens the door to many things that have implications for Europe and we know that the regulators are worried about that.

Um, so and we also know that the regulation is slow compared with the velocity of the crypto space. So it is true. I agree. Then we need to start discussing about all all of these topics especially the ones that are moving globally.

All right. Thank you. Oh yeah. I guess my very quick final thought would be, you know, what I've said. Um the rule book is clear and let's just keep innovating and investing in in in products that that clients and customers across the EU want because that's that's ultimately that will what will continue to drive interest in the space.

So that and that's why I work in it and believe in it. So that's it.

Maybe from my side. I mean um just one one or two two sentences to the to the to the global stage you know I mean uh US is coming now and they do it always I have the feeling like EU does always want to do micromanagement you know they don't they would really to even define how we need to assess a white paper what not you know I mean really and and US is just giving a guardrails you know customer projection for sure GD bar what not but then the the the market can can can can grow. Same for example for Mina doesn't matter if VR adm all these guys you know they are very innovative for example I mean Austria was invented the the land register 200 years ago you know Vra brought it on blockchain you know already now so you can transfer ownership of land and property on chain which is a is a game change at the end of the day and don't forget about even APE and don't forget about China China will also uh adapt at one point in time So, and Europe still is the old lady more or less, you know, sorry, but um tries to really to protect to the to the ultimate end, you know, and maybe that's that's hindering innovation. And when it comes to innovation, we are also talking about new products. We're talking about tokenization of real world assets.

We have the DTSS regime which is just in place, but already is going to be reviewed again and maybe they skip it afterwards. Um but we really need to also have some room for innovation in Europe. So we should really think of starting the discussions maybe in that direction you know um and at the end of the day um um our customers should be safe. So it's again about trust. So trust is everything for us uh and the compliance as well.

So, I'm very much looking forward to also with you guys from Blockchain for Europe doing a great job here educating the policy makers to go in the in the in the right direction.

Yeah.

Thank you for the shout out, Christian.

Yeah. Well, do I still have some time? Yeah. Okay. I'm thinking uh I I think you know pretty much is education.

Uh I would say that's that's key. uh on the supervisory side uh having the right tools uh I you know I can't stop saying datadriven approach and riskbased supervisory approach I think is the best uh for that of course you need the right tools and and and and then for the for the global spec right um if we if we play above the bar right with high standards I think we can be above regulation so by having you know very high-end tools that allows you to protect on the security side, on the compliance side, and also on the fraud side, which we haven't talked about. And with all that, you know, yeah, I mean, uh, if you play above and you don't, you know, just playing at the edge just to tick the box that you do have something uh that complies with, then you you can be safe.

Yeah, great. I think we can uh end on this uh positive note. Thanks so much to our panelists. Thanks to our audience for listening to our conversation. Thanks to Merge for giving us also a few extra minutes.

I feel of course they need to close this off. Send everybody to lunch. And uh keep an eye of course on Mika and everything that is happening in Brussels and the work that we're doing with the European Union because of course it's not over. There is a lot to do still but it's great to have some great people that are doing that job for the crypto industry. So big round of applause.

Thank you so much.