Our
experience

E – money tokens issuance

For leading e-money institution we provide legal services applicable legal frameworks, regulatory standards, and industry best practices governing e-money and cryptoasset operations. We provided end-to-end legal and advisory to a leading client in connection with the issuance of Electronic Money Tokens (EMT), qualified as electronic money under the EU Markets in Crypto-Assets Regulation (MiCA) and the Electronic Money Directive (EMD2).

Our engagement included the comprehensive preparation of the whitepaper, ensuring full regulatory compliance with Articles 51–53 of MiCA. A distinctive feature of the project was our close cooperation with the client’s IT and blockchain development team to ensure the technological sections of the whitepaper accurately described: the DLT / blockchain infrastructure, the architecture of smart contracts, the security mechanisms ensuring token integrity and user protection.

We helped translate complex technical concepts into regulatory-compliant and user-friendly language, fully aligned with MiCA’s disclosure standards. We also advised on the regulatory notification process, preparing the client for submission of the whitepaper to the competent supervisory authority prior to the public offering. Thanks to our holistic approach, the client received a fully compliant, regulator-ready whitepaper, positioning them to legally launch and distribute EMTs across the European Union. Our work strengthened the client’s regulatory standing and enhanced market trust in their token offering.

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.

Additionally, we prepared the full regulatory notification package and assisted in managing communications with KNF, including responses to supervisory inquiries and legal clarification of the issuance model.

This was a highly complex, multidisciplinary project requiring expertise in: EU financial services regulation (MiCA, EMD2, PSD2), blockchain and DLT technologies, consumer protection, AML/KYC, and data privacy (GDPR), regulatory engagement and cross-functional collaboration with technical teams.