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What we think
We distil and translate the latest developments in public policy, regulation and governance
Strategic Implications of the EU Market Integration Package on Crypto-Asset Service Provider Business Models and Revenue Architectures
1. Executive Summary: 1. The Macro-Strategic Shift: From “Move Fast” to Industrial Policy The EU’s “Market Integration and Supervision” package (MiCA 2.0) represents a fundamental pivot from consumer protection to geopolitical industrial strategy. Grounded in the Draghi Report’s call to close the EU’s investment gap, this regulation aims to “sanitise” the crypto sector to mobilise household savings. Strategic Implication: The era of “move fast and break things” is foreclosed.
James Ross
Dec 16, 202516 min read
SwanFS: Key Considerations for Crypto Asset Service Providers, arising from recent developments
I. Executive Summary This week’s developments signal an evolution in the regulatory environment, shifting from theoretical risk to tangible enforcement actions and notable strategic divergence among key jurisdictions. For Crypto Asset Service Providers (CASPs), the global landscape now presents three primary areas of focus that merit careful consideration for our operational, product, and legal strategies. Enforcement and AML/CTF Scrutiny. The €21.46 million fine imposed by
James Ross
Nov 9, 202515 min read
SwanFS Report on October 2025 Regulatory Developments: Potential Impacts on Crypto-Asset Service Provider Business Models
Executive Summary October 2025 marked a material shift in the regulatory landscape for the crypto-asset industry, moving from high-level principles to binding technical implementation. The fragmented, principles-based guidance of the past has been supplanted by a wave of detailed, binding Regulatory Technical Standards (RTS), supervisory Q&As, and thematic reports. This transition fundamentally alters the operational, prudential, and economic landscape for Crypto-Asset Servic
James Ross
Nov 2, 20258 min read
Global Regulatory Developments - March 2025
March 2025 witnessed significant regulatory advancements in the global financial sector, particularly concerning digital finance. Key...
James Ross
Apr 2, 20257 min read
ESMA's 2025 Agenda: A Deep Dive into Issuer Disclosure and Beyond - Part 3
The European Securities and Markets Authority (ESMA) has unveiled its 2025 work program, setting a demanding agenda for financial firms...
James Ross
Oct 4, 20243 min read
ESMA's 2025 Agenda: A Deep Dive into Impacts for Investment Managers and Service Providers - Part 2
The European Securities and Markets Authority (ESMA) has set an ambitious agenda for 2025, with significant implications for investment...
James Ross
Oct 3, 20242 min read
ESMA's 2025 Work Program: A Comprehensive Guide for Financial Firms Part One
The European Securities and Markets Authority (ESMA) has set an ambitious agenda for 2025, with a work program that covers a wide range...
James Ross
Oct 2, 202414 min read
August Regulatory Roundup: The Global Push for Resilience and Digital Transformation
August saw a significant uptick in regulatory activity worldwide, with a clear focus on fortifying operational resilience, navigating the...
James Ross
Aug 31, 20242 min read
Decoding DeFi: ESMA Sheds Light on Smart Contract Complexity
The world of Decentralised Finance (DeFi) is booming and powered by the innovative capabilities of smart contracts. However, the rapid...
James Ross
Aug 2, 20242 min read
MiCA Q&A Updates: Key Points & Firm Implications
The European Securities and Markets Authority (ESMA) has released a series of Q&A updates regarding the Markets in Crypto-Assets (MiCA)...
James Ross
Jul 30, 20242 min read
ESMA's Draft Standards on Conflicts of Interest: A New Era of Transparency for Crypto-Asset Service Providers (CASPs)
The European Securities and Markets Authority (ESMA) has taken a significant step towards greater transparency and investor protection in...
James Ross
Jun 9, 20242 min read
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The posts listed on the 'What we think' webpages are our interpretation of key developments we have been reading about. They should not be considered legal, regulatory or other advice. Contact us if you want to understand the impact of public policy, regulation and governance changes for you.
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