E money token issuance
We advised a licensed Polish e-money institution, on a strategic, cross-border initiative involving the regulatory structuring, operational planning, and legal implementation of MiCA-compliant Electronic Money Tokens (EMTs) intended for issuance and trading across Asia.
The project focused on enabling the joint issuance of an EMT by our client and its international partner, ensuring full compliance with the Markets in Crypto-Assets Regulation (MiCA), operational readiness, and seamless integration with both banking infrastructure and blockchain-based systems.
We provided comprehensive regulatory structuring support, including the design of the joint issuance framework under MiCA and legal alignment with the requirements applicable to EMT issuers. We guided our client through the regulatory notification process before the Polish Financial Supervision Authority (KNF) concerning the stablecoin’s issuance structure and partnership model, while also monitoring regulatory risks and compliance feasibility in light of evolving EU standards.
Our firm also advised on the drafting, review, and negotiation of the partnership agreement governing the issuance and redemption of the EMT between client and its global counterparty.
A key component of our engagement was the co-development and legal review of core documentation for this project, including:
- the MiCA-compliant whitepaper for stablecoin issuance,
- redemption and recovery plans,
- customer terms and conditions,
- and internal policies covering AML/CFT, GDPR, and IT security.
We were also involved in shaping a multi-phase onboarding and operational plan, supporting:
- the setup of EEA-based fiat settlement accounts,
- the implementation of updated AML/CFT and risk frameworks, and
- the integration and testing of cross-platform IT infrastructure.
This project positions our client to become one of the first regulated entities in the EU to offer a MiCA-compliant EMT-based stablecoin, enabling use by both retail and institutional customers. Our legal team ensured that the solution met all regulatory requirements while supporting commercial scalability and operational security.
The engagement demonstrates our expertise in complex, multi-jurisdictional legal matters, encompassing EMI licensing, MiCA implementation, AML/CFT compliance, international legal coordination, and blockchain integration.
See also:
We are advising a Lithuanian-licensed Electronic Money Institution, on the design and full regulatory implementation of its euro denominated Electronic Money Token (EURM) in compliance with EU Markets in Crypto Assets Regulation (MiCA).
We advised a polish comapny on obtaining Bank of Lithuania approval for the acquisition of 100% of the shares in a licensed Electronic Money Institution (EMI). Our work focused on the preparation of a comprehensive change of control application package, including ultimate beneficial ownership, financial standing, business plan impact, source of funds, and fit and proper assessments for management and key function holders. We also coordinated all regulator Q&A and ensured the submission met the highest supervisory standards.