Organizational structure under MiCA regulation

About the MiCA Guide

When MiCA was first announced, most crypto companies treated it like background noise or something to “deal with later.” But now we’re here, when it’s a perfect time to prepare your team.

The Evotym MiCA guide was developed to help founders, compliance leads, and advisors make sense of what MiCA means in practical terms. It reflects ongoing conversations with teams navigating licensing, governance, and role definition.

This is the moment to step back and check where your structure really stands. The MiCA guide is designed to help you identify potential gaps, revisit unclear responsibilities, and strengthen areas that may have been overlooked. It’s a chance to review your setup before the pressure hits - and before assumptions turn into regulatory delays, repeated feedback loops, or missed expectations.

This blog breaks down what we’re seeing on the ground, and how to approach MiCA not just as a regulation, but as an opportunity to build a better, more resilient company.

Let’s Start with the Obvious: Structure Isn’t Optional

Every CASP application now comes with the same question from regulators:

“Who’s actually responsible for this?”

That’s where many companies hit a wall. They have talent. But it’s often overextended, spread across functions, or too detached from operations to be credible in front of a regulator.

This leads to many questions and uncertainties:

• How do you secure the license?
• Who do you need on your team?
• Where do you even find the right experts?

In our guide, you as a founder or top manager, or a consulting firm or independent advisor, will be able to find:

• Top 3 things to understand before planning your MiCA-compliant team
• Additional factors to consider when planning your organizational structure and hiring
• A full list of essential functions - and what regulators expect from each
• An example of a real organizational structure used in a licensing case

It also includes insights tailored to different regulatory environments, with real case examples that bring these requirements to life:

• An example of an organizational structure created for the Lithuanian regulator as part of a CASP license application for a specific business.
• Where a local Deputy CEO is required.
• What roles can be outsourced (and what can’t be combined).

This kind of guidance can save you weeks of confusion, unnecessary back-and-forth with regulators, and costly delays in your licensing process.

But Knowing What Roles You Need Isn’t Enough

This is where most teams stop - and where things get risky.

Many crypto companies assign compliance responsibilities without providing access to focused, up-to-date training - especially in areas like in Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Sanctions compliance.  These areas are deeply connected to the day-to-day operations of a crypto business.

One practical resource worth considering is a course built specifically for crypto companies: Annual Anti-Money Laundering and Counter-Terrorist Financing Training for Crypto-Asset Service Providers. It offers a structured, annual training path aligned with MiCA and AMLR: covers red flags, risk recognition, the Travel Rule, and how enforcement is unfolding across the industry.

If you're already working on building internal knowledge and preparing for licensing, this type of practical training can help teams stay aligned and confident in what they’re doing.

It’s important that your team knows how to handle compliance challenges in everyday scenarios - across onboarding, transaction monitoring, and internal reviews. Everyone involved should be able to identify risks and take appropriate action based on clear procedures.

What We’re Seeing Right Now

As MiCA implementation progresses, teams across the crypto industry are trying to make sense of the practical changes. This is the last moment to prepare - to spot the gaps, recheck your structure, and assess how ready your team really is for MiCA as a whole.

In conversations with founders, legal leads, and compliance professionals, we often hear the same concerns:

• What does "substance" really mean for our team structure?
• How do we demonstrate that our governance setup fits our business model?
• Are we missing roles that regulators expect to see?

Even companies with strong internal experience are finding that licensing requirements demand a different level of documentation, clarity, and role separation. These topics come up often in license application feedback, revision requests, and follow-up questions from regulators.

To make these questions easier to navigate, several leading experts contributed to our MiCA guide:

• Viktorija Poluektova - Global Chief Risk & Compliance Officer (CRCO), Founder of Regusolutions
• Anna Rudakova - Managing Partner at Regusafe and Head of Partnerships at Platforma365
• Roman Laidinen - Certified Internal & Information Systems Auditor
• Chloe White - A leading expert in virtual asset policy

Their collective insights helped shape the guide into a practical, approachable resource that breaks down what MiCA means in real terms - for governance, compliance, and team design.

We’re not pointing to a fixed checklist. But there’s clear value in taking time early on to define responsibilities, map your organizational structure against regulatory expectations, and make sure team members are ready to speak to their roles - in writing, in interviews, and in practice.

Our Advice to Crypto Founders? Don’t Wait.

It’s a good time to pause, revisit your structure, and see what still needs attention. MiCA introduces a set of expectations that will impact how teams are built, roles are defined, and oversight is demonstrated - and it’s worth identifying and addressing those gaps now.

The companies doing this right are:

• Reviewing their current team setup to identify potential gaps or overlaps
• Getting clarity on who owns what
• Upskilling their team members
• Documenting responsibilities - in a way regulators understand
• Bringing in outside help where needed (outsourced MLRO, legal, infosec, etc.)

The Evotym MiCA guide offers a practical starting point to help you align your team setup with MiCA’s expectations and avoid common oversights in structure and responsibilities.

And if you’re not sure where to start: hiring, structuring, or training - that’s what we’re here for.

Download the Guide

Explore the Regu-Learn Training

Talk to us about building your MiCA team

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