CASP

CASP (Crypto-Asset Service Provider) is the regulated-entity category defined by the EU MiCA regulation (Markets in Crypto-Assets, Regulation (EU) 2023/1114). MiCA uses this label in place of the earlier FATF term VASP. A CASP is any firm that professionally provides regulated crypto-asset services in the EU — trading, custody, exchange, order execution, transfers on behalf of clients, and order reception.

What services trigger CASP status

Article 3 of MiCA lists roughly a dozen regulated services. Performing even one of them inside the EU requires a CASP licence:

• custody and administration of crypto-assets on behalf of clients;
• operation of a trading platform;
• exchange of crypto-assets for funds or for other crypto-assets;
• execution of orders for clients;
• reception and transmission of orders (brokerage);
• placement of crypto-assets;
• advice, portfolio management;
• transfer services for crypto-assets on behalf of clients.

Non-custodial wallets and DEXs without a back office fall outside the CASP definition on paper, but it is a grey area. ESMA guidance through 2024–2025 has flagged the risk that requirements may extend to “effective operators” of decentralized front-ends.

Obligations of a licensed CASP

A CASP must meet a stack of requirements:

• authorisation by a national regulator in one EU member state, with passporting across the bloc;
• minimum capital depending on the service (EUR 50k to 150k);
• internal KYC, AML, and Travel Rule procedures (Regulation EU 2023/1113);
• segregation of client and own assets, reserving, mandatory reporting to ESMA;
• token disclosures before listing, liability for misleading communications.

Relevance to the TON ecosystem

Any service that lets EU residents buy TON, USDT-jetton, NFTs, or other crypto-assets for fiat must either be a CASP itself or work via a CASP partner. This has already affected European exchanges with TON pairs (Bitstamp, Bitvavo, Kraken, OKX-EU and others) as well as fiat gateways inside Telegram Wallet. Local exchanges continue to operate but are migrating to the licensed model.

Timeline

• Stablecoin block (ART / EMT tokens) — from 30 June 2024.
• Full CASP regime — from 30 December 2024.
• Transitional period for existing providers — until 30 December 2025 (extended differently across member states).

This is not legal advice; the actual obligations depend on the country and type of service.