Sygnum Europe AG Authorized as CASP Under MiCAR

The FMA Liechtenstein has granted Sygnum Europe AG a full crypto-asset service provider (CASP) authorization under the Markets in Crypto-Assets Regulation (MiCAR), effective 26 June 2026. For accounting firms and CFOs advising clients with European crypto exposure, the registration marks another concrete step in MiCAR's rollout across EEA jurisdictions and confirms that Liechtenstein is processing authorizations in earnest.

What the FMA Liechtenstein Decided

The Entity and the Legal Basis

Sygnum Europe AG, registered in Vaduz under company number FL-0002.722.200-8, obtained its CASP authorization pursuant to Article 63 of Regulation (EU) 2023/1114, the core MiCAR text that came into full force across the EU and EEA in late 2024. The FMA Liechtenstein, the principality's integrated financial market regulator, is the competent authority for such registrations in that jurisdiction.

Liechtenstein's membership in the European Economic Area means that a CASP authorization granted there carries the MiCAR passporting rights available to any EU-authorized firm. That is a practically important point: a firm authorized in Vaduz can passport crypto-asset services across EU member states without seeking separate national licenses.

Services Covered by the Authorization

The FMA's notice confirms that the authorization covers crypto-asset services as defined under MiCAR, though the specific service categories listed in the original notice were not reproduced in full in the available public text. Under MiCAR, Article 3 defines the spectrum of covered services, which includes custody, operation of trading platforms, exchange services, order execution, advice, and portfolio management, among others. Firms checking counterparty credentials should request the full authorization document from the FMA or the entity directly to confirm which specific services apply.

Why This Matters for Firms and CFOs

MiCAR Passporting and Counterparty Due Diligence

A MiCAR authorization is no longer a future compliance objective. Regulators are granting, and in some cases refusing or revoking, licenses now. Accounting firms handling clients that transact with crypto-asset service providers need to verify those counterparties hold valid authorizations. An entity providing crypto-asset services inside the EEA without a MiCAR license is operating unlawfully, creating exposure for clients who rely on it and potential liability for advisers who fail to flag the risk.

The FMA has a public record of being willing to take the opposite action too. FMA Liechtenstein's earlier enforcement actions against fund service providers illustrate that authorization is not automatic and that the regulator actively monitors compliance after the fact.

Passporting Across the EEA

A Liechtenstein-based CASP can notify competent authorities in other EEA states and begin providing services cross-border. For clients based in Luxembourg or other EU jurisdictions, this is directly relevant: they may receive services from Liechtenstein-registered entities without those entities holding a local license. Advisers should check that any such arrangement complies with the passporting notification requirements and that the home-state authorization actually covers the services being delivered.

The broader enforcement picture is just as important. How ESMA ordered unauthorised CASPs to wind down as transitional periods closed showed that regulators across the bloc will act where firms have not completed their authorizations. The window for operating under transitional arrangements is firmly closed.

Compliance Checklist for Advisers

Key Steps When a Client Uses a CASP

The following steps reflect good practice under MiCAR and general AML obligations. They are not exhaustive and should be read alongside the specific requirements of the applicable jurisdiction.

• Confirm the counterparty CASP appears on the relevant national competent authority's public register or ESMA's forthcoming central register of MiCAR-authorized entities.
• Identify which specific crypto-asset services are covered by the authorization and cross-check against the services your client is actually receiving.
• Where the CASP is passporting from another EEA state, confirm that the passporting notification has been filed with the host-state authority.
• Document the verification and retain it as part of the client file.
• Repeat the check periodically: MiCAR authorizations can be varied, suspended, or revoked.

Frequently Asked Questions

What is a MiCAR CASP authorization?

It is a formal licence granted by a national competent authority under Regulation (EU) 2023/1114 (MiCAR) permitting a firm to provide one or more crypto-asset services within the EEA. Without it, a firm cannot lawfully offer those services to clients in any EU or EEA member state.

Does an FMA Liechtenstein authorization allow a firm to operate across the EU?

Yes. Liechtenstein is an EEA member, so a MiCAR authorization granted by the FMA carries the same passporting rights as one granted by any EU national competent authority. The firm must still follow the notification procedure before providing services cross-border.

How can we verify whether a CASP we deal with is authorized?

Check the public register maintained by the relevant national competent authority, such as the FMA in Liechtenstein. ESMA is also building a central EU register. Always verify the specific services covered, not just the existence of an authorization.

What happens if a client is using an unauthorized CASP?

Operating without MiCAR authorization is unlawful. There are potential regulatory, reputational, and AML/CFT risks for clients dealing with unauthorized entities. Advisers should document their due diligence and flag the issue to the client as soon as it is identified.

Is Sygnum Europe AG the same as Sygnum Bank AG in Switzerland?

They share a corporate group but are separate legal entities. Sygnum Europe AG is the Liechtenstein-registered entity that holds this specific MiCAR authorization. Always verify the exact legal entity name and registration number when checking authorizations.

Source: FMA Liechtenstein