E – money token issuance
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).
Our engagement included drafting the complete MiCA compliant whitepaper (Articles 48 and 51–53), ensuring clear disclosures on the EURM’s 1:1 collateralisation with fiat reserves, redemption rights, risk factors, technology infrastructure and safeguarding arrangements.
We also support the client in aligning all internal policies and governance frameworks with supervisory expectations, including AML/CFT, GDPR, IT security, operational resilience (DORA alignment) and token redemption procedures. Our work involved close cooperation with NS Pay’s IT and blockchain development teams to ensure the whitepaper’s technical sections (smart contract design, DLT architecture, compliance hooks) met ESMA standards for fairness, clarity and accuracy.
In parallel, we are preparing the full regulatory notification package for submission to the Bank of Lithuania, coordinated passporting under Article 123 MiCA for distribution across the EEA, and engaged in supervisory communications. We also reviewed customer facing documentation (terms & conditions, redemption and recovery plans) and provided strategic guidance on the product launch and marketing framework.
The project positions NS Pay as a first mover issuer of fully MiCA compliant EMTs in the European Union, enhancing its regulatory standing and enabling a scalable, cross border digital euro solution for merchants, fintechs and consumers.
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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.
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.