A “death spell” recipe for any early-stage venture-funded company is being dormant and unable to ship products for extended periods of time and with the economic recession setting in, and uncertainty around the licensing process, as a team of mostly “third-country nationals” from various parts of the world who moved their entire lives to a new country, things were tough. But here’s how we went about it –

1. As a small team, working together in person to iterate rapidly on the product, in the same time zone was a huge must-have. Qualifying for the startup program and jumping through immigration hoops, we planned the move for key team members. (The country’s marketing department and its embassies around the world are severely out of sync. This process is a lot harder than it is marketed to be)
2. Began building and educating the entire team on the compliance framework, accountability, and the way our operations would change, directly impacting the fronts of product, business, and even marketing. Practically, this means translating tens of pages of legal text around the company’s internal rules of procedures into code and manual labor with crystal clear awareness for everyone involved about what is at stake. Overly simplifying it — The final application was altogether over 200 pages of documentation explaining exactly what we do, how we do it, why we’re compliant, and how we were to meet all the requirements of the law. Here is where there is the most room for error as preparing documentation does not equate to arbitrary templates and generic compliance policies. Being able to clearly answer and back up every single claim made on any single page with facts and answers which range from various risk-related matters to deep technical implementation matters was the end result — Which logically makes sense in this industry with every business being inherently organized differently.
3. Deeply understand what the law is trying to achieve and begin building out a compliance team — A scarce resource in a highly competitive market in a small non-English speaking country.
4. Solicited, negotiated, and built solutions with well-positioned custodians, exchanges, banking providers, and card issuers. Given the nature of the product — Either we would wait until the license was granted to build these partnerships we needed to build the core application logic (No banking institution will enable access to their product without being regulated for a business of our nature) or build on what we had, mimicking a live environment as best possible, to further our business efforts in enabling early adopters to start building, despite the FUD. We did the latter and it’s here.

One of the biggest misconceptions we’ve seen is in the meaning of what a “license” entails. Especially most digital asset companies we’ve come across tend to feature founders with a mix of business and technical skills and today, pan Europe with the current geopolitical situation and regulators cracking down (even going as far as retro-actively applying laws), obtaining a “license” to operate in this industry is an arduous and risky endeavor, making it all the more important to build a team and product around the framework of legal requirements. With the MiCA legislation set to apply pan-Europe in 2023, we’re more than well positioned to fully comply and meet these requirements to continue shipping products. Effectively, for any company going through the process, one can expect to dedicate well over €1M to the task, implementing gnarly compliance-related infrastructure into your core codebase and around 12 months of fear, uncertainty, and doubt before you can even finalize your product and ship it.