Anne-Grace Kleczewski & Anne-Lorinne Mognetti from MME on Getting Ready for MiCA

[00:00:00] Umar: Welcome to The Accountant Quits, brought to you by the Web3 CFO Club, a community by Request Finance. With a curated community of Web3 CFOs from companies like Aave, The Sandbox, Binance, ConsenSys, Ledger, and many more, joining this club will allow you to network and learn best practices on Web3 financial operations.

[00:00:23] Umar: On The Accountant Quits podcast, we discuss how blockchain will impact the accounting professions and how accountants should prepare themselves for the future of work. My name is Umar, your host, and even if some might refer to me as the accountant gone rogue, my job is to provide you with the blockchain knowledge that you need that will be relevant for the accounting industry as a whole. 

[00:00:47] Umar: Welcome to episode 67, the deadline for the new crypto regulation in the EU termed the Market in Crypto Assets or short for MiCA is fast approaching and many are wondering what exactly does MiCA entail and how can you prepare for it? For starters, MiCA applies to a broad range of entities providing services related to crypto, including exchanges, custodians, wallet providers, brokers, investment firms, and more.

[00:01:17] Umar: There are two key compliance deadlines based on the nature of your services, June and December 2024. Now, in the absence of a dedicated compliance specialist, the task of ensuring your web3 startup is MiCA ready might fall on you, the Head of Operations or Finance. Being proactive and seeking legal expertise early is crucial.

[00:01:42] Umar: To help us get prepared for MiCA, today I'm thrilled to welcome Anne-Grace Kleczewski and Anne-Lorinne Mognetti from MME. MME has been instrumental in the development of the Crypto Valley ecosystem and is a leading Swiss firm offering comprehensive legal, tax and compliance services for digital assets and blockchain technology.

[00:02:04] Umar: MME helped a few of the most well-known projects conduct their ICO, including Ethereum, Cosmos, and Tezos.

[00:02:12] Umar: In this episode today you will learn what is MiCA and why it's being introduced, the requirements for MiCA compliance, MiCA's interpretation for DeFi and DAOs, how MiCA compares to current crypto regulations and much more. 

[00:02:29] Umar: Anne-Grace and Anne-Lorinne, welcome and thank you both for joining us today.

[00:02:33] Umar: So to start, I'd like to ask my guests, could you both share a little bit about your background? How you first became interested with blockchains and the projects that you're currently involved with today. Anne-Grace, I know you're working both for MME and the Keom protocol. 

[00:02:51] Anne-Grace: Exactly. So I guess I will start on that one.

[00:02:54] Anne-Grace: My background is a bit diverse. On one hand, very traditional, started as a lawyer in M&A, traditional financial regulations in Belgium first, so rather EU oriented context. But I also worked a lot on new technologies and the sharing economy and all the collaborative practices as these were fostered by centralized web2 platforms when there was a sharing economy craze back in the time.

[00:03:19] Anne-Grace: So this, this makes a very traditional with more this, ideology of let's share, create a better alternative system, which looks like a good way to prepare grounds for a web3 adventure, right? Because we have both, we have financial regulations and this vision of a better world, at the end of the day.

[00:03:37] Anne-Grace: How did I get interested with blockchain? Well, because someone really tried to convince me very hard that blockchain is the future. And, did not manage to. So at some point, I was so disappointed with that. Like, how come people get excited and I still don't see the point in it? Let's read a book about it.

[00:03:54] Anne-Grace: And that book started it all. I just, all of a sudden it clicked. I was like, I can definitely see the potential there. Like all the things we can do with smart contracts. So the adventure started that way. I was quite lucky to find a law firm that, needed a lawyer to advise on this kind of projects.

[00:04:09] Anne-Grace: And the deeper you get into the space, the more you get out also to conferences, to meet builders, you just get the virus. I don't want to get out of the ecosystem anymore. So, I ended up advising a lot of projects, and also starting one of, a DeFi project actually. So Keom protocol, as you mentioned, where we want to change the way trading is conceived instead of having the option between traditional taxes, the way they operate, with pools and then having order books that are centralized or are decentralized bots, black boxes, or have like other issues because for instance, it's too slow. You have latency and so on trying to create a sovereign exchange where you utilize ZK proofs to have a better trading environment to make sure there's no front running, but it's still super fast.

[00:04:59] Anne-Grace: So it's as fast as Binance, for example, but it's non custodial. Basically trying to build a new tool for traders so they feel empowered without needing to trust a centralized entity, but still have enough guarantees to feel as, confident as they may feel in some cases with, more traditional actors and, and CEXs basically.

[00:05:21] Anne-Grace: But just one of the projects. But DeFi is really my core interest, trying to find how we can build a better financial system, thanks to web3. 

[00:05:29] Umar: Perfect. And can I ask you what was the name of that book you stumbled on? 

[00:05:34] Anne-Grace: No, there's a secret. 

[00:05:35] Umar: Oh, it's a secret. All right. 

[00:05:40] Anne-Grace: It was very basic. So I always say I will not mention the title because it's one of those very basic introductions.

[00:05:48] Anne-Grace: Explain how Bitcoin works and how smart contracts works. But, yeah, it all starts with Bitcoin. So this is, maybe a good call to people start with anything. Like even the most basic lecture is sometimes a very good one. But also we all started like that. So we all need to start like that. But now it's like, it's a secret by now.

[00:06:09] Umar: I Googled blockchain for dummies in the beginning. 

[00:06:12] Anne-Grace: That's a good start too. Yeah. But it wasn't that one for me. 

[00:06:17] Umar: Perfect. Thanks for sharing. And Anne-Lorinne? 

[00:06:21] Anne-Lorinne: Well, first of all, thanks a lot for the invitation, Umar, because I'm really thrilled to be here today with you. So a bit about my background. So back actually in the days when I was in business school in France, I managed somehow, don't ask me how, but to miss out the whole internship at the start of craze.

[00:06:40] Anne-Lorinne: And I managed actually to make up for lost time in the prettiest and coolest way by actually landing at Ledger when I was, a trainee lawyer in Paris, and as I went down actually the rabbit hole, I thought things couldn't get more interesting. And that's where actually I found, like some papers and how interesting the crypto valley was.

[00:07:02] Anne-Lorinne: And that's where actually I came across the path of, Andreas, who is like the Co-Founder of the, FinTech team at MME. And, he definitely saw that my French qualification was not going like to prevent me from advising people with Swiss law, because I mean, both system are like code based law.

[00:07:20] Anne-Lorinne: And so we made the bet actually to start this, experiment and just the next thing I know, I'm like, navigating the peaks and the valley of both EU and the Swiss law autonomy. 

[00:07:33] Umar: Perfect. Thanks for sharing. So, why don't we get started with, the topic for today, which is, on MiCA.

[00:07:41] Umar: So as a refresher, could you explain a little bit about what is MiCA, why it's being introduced and given this podcast is listened by accountants, for large part, could you explain why it's also relevant for the accountants listening? 

[00:07:57] Anne-Lorinne: Yeah, absolutely. but if you allow me, I would maybe just start, by tackling the why question because I think it's always the most interesting one and the most intriguing one.

[00:08:08] Because it's really like shines the lawmaker intention and like the context in which the regulation was drafted. And it's always very interesting actually to have this background element if you really want to understand it. And I think MiCA goal was actually, very clear from the beginning.

[00:08:25] Anne-Lorinne: It was to tame the crypto wild west and to tame the crypto wild west is not like a catchy phrase that I just made up, , it's a quote that actually comes from the, French minister of the economy. And so that reminds us actually that while MiCA was being drafted, the crypto industry was marked by different episodes, such as like jaw dropping bankruptcies with Celsius, with FTX.

[00:08:55] Anne-Lorinne: Then we had all this NFT craze, we had also back in the days, Facebook stab, at a stable coin, which the European authorities didn't really sit well with. And so these elements actually really cast the crypto sector as like the wild child that really needed to be educated and locked down.

[00:09:17] Anne-Lorinne: And So MiCA is actually like the widest umbrella you can come with in order like to establish a united set like of rules if you are like a crypto asset issuer or if you are providing crypto assets across EU. And for the people who are listening to us, so, be it like, accountants, CFO and other individuals who are like in the finance sector, I think it's always very interesting to know and to be able to qualify the elements actually you will have in your balance sheet, whether it will be like a payment tool or whether it's something it can be off your balance sheet, as it always has like a quite a, an impact at the end of the year.

[00:09:57] Anne-Grace: It's basically about knowing what you do and not fearing the beast or the monster. This crypto is often, considered as this evil thing. We don't know what we're touching. But if we have definitions at the end of the day and you put each token in the right basket, you know, that's not all of crypto is the same.

[00:10:13] Anne-Grace: We have categories, some are riskier, some interact in a certain way. Some providers are regulated, others not, but at least you, you have some clarity there and you don't just see this vague desert or this, let's say open waters I would rather say. Open waters where no one really knows what kind of fish they will meet at the water.

[00:10:30] Anne-Grace: Is it a shark or what exactly is there? 

[00:10:33] Umar: You're exactly right. I mean, accountants before interacting with digital assets, they want to be clear on the accounting standards, but also on the regulations. 

[00:10:42] Umar: So moving on to the scope, MiCA applies to different asset service providers. And like I mentioned in the intro, those could be businesses such as crypto exchanges, custodians, wallet providers, asset management firms, and a few more. Now for companies falling under the definition of what MiCA prescribes, what would be the MiCA requirements for compliance?

[00:11:06] Anne-Lorinne: So just as a reminder, first, maybe like, the law actually provide for a list of crypto services, like which are regulated under MiCA. So you say perfectly, so it can be custodian, it can be exchange, It can also be like the execution of orders. So, for crypto assets. 

[00:11:24] Anne-Lorinne: And also the law provides for definition on that. So you can really have a clear idea of what is in and what is out. And for example, you can, you can already know that actors that, do not have any custody or control over crypto assets or miners, validators, provider of API, block explorer, all these people actually are not really the people who are like targeted by the law.

[00:11:48] Anne-Lorinne: So that should be like the first element like to remind and then concerning like what you need to do. So if you are actually like stepping, into the realm of the regulated, services under MiCA, then you will really need to gear up because you will need actually to secure a license and to secure a license, you have to prove to the regulator that you have everything under control and that everything is in order from governance arrangement to internal control mechanism, including AML procedure. And also, for example, what is your policy, for example, to segregate your asset and your funds from your client funds and assets. 

[00:12:31] Anne-Lorinne: But remember, so securing the license is only the beginning of the journey and to hold on to it, you must continuously meet a couple of requirements.

[00:12:40] Anne-Lorinne: For example, you need to maintain prudential requirements and plan an orderly wind up. So we definitely here see, for example, like the ghost of FTX and Celsius in the air hanging there. And I think you can definitely say that if you want to be MiCA compliance, you really need to get your ducks in a row.

[00:13:02] Anne-Lorinne: And regarding like the scope, I think, Anne-Grace can share with us like some very interesting, insight regarding actually the place of DeFi in it. 

[00:13:11] Anne-Grace: Yes, because even just the requirements and obligations you mentioned, Anne-Lorinne, make us wonder, what about decentralized projects? Who would secure a license?

[00:13:21] Anne-Grace: Would it be a wrapper of some DAO? Like, how are they in a position to comply with the requirements stemming from MiCA? What kind of wind up plan would be possible? Who would be overseeing what and who would be in control? Because most of the time, major functions are supposed to be decentralized.

[00:13:39] Anne-Grace: As a quick reminder, all the regulations we know rely on the idea there is a centralized entity in finance who can oversee, implement, communicate with the authorities, react to what the authorities request. So we need the centralized actor with enough power. The problem is that we have an increasing number of projects where key elements are supposed to be decentralized. 

[00:14:03] Anne-Grace: And MiCA somehow takes it into account, but in a very, interesting fashion, because MiCA excludes fully decentralized and disintermediated projects from its scope. The question now is, what does that mean concretely? And which projects are effectively excluded, for sure.

[00:14:20] Anne-Grace: Well, fully decentralized. When we look at the states, of projects that identify as DeFi in practice, while there'll be only a handful of them that can actually claim to be fully decentralized. There is a whole list of potential centralization points that can be pinpointed, be it a centralized interface, you have a multisig, but potentially there's still some sort of centralized kill switch, and this kind of things.

[00:14:46] Anne-Grace: Well, like some decisions, for example, are implemented in a centralized fashion while others, you ask the community, like how many projects have a DAO without a clear charter, where you basically don't know what the DAO is supposed to vote on. And you have a lot of diverse votes, but then you realize that some decisions were implemented without a vote.

[00:15:07] Anne-Grace: And you don't have any clarity there. So how do we handle those? I would say hybrids, systems that are on what we like to call the decentralization spectrum, because potentially they want to decentralize more, or it's not even desirable for them to decentralize more because at the end of the day, do we want to handle billions through an entity that, where everything is handled by a DAO.

[00:15:30] Anne-Grace: This is a more philosophical question. So how do we handle those hybrids? And we don't have an answer yet. And depending on the answer that will be provided at the EU level, we can hope for a report by the end of the day, clarifying the vision policy approach, for DeFi, but this report will be just a report. So it's not yet a solution. 

[00:15:50] Anne-Grace: The answer could be, there's nothing to be done there, which I believe could be dangerous from some aspects, Or the answer could be, this is the threshold and if you comply with that threshold, you are deemed to be DeFi according to the MiCA standard.

[00:16:05] Anne-Grace: And you're not subject to the requirements under MiCA. You don't need to ask for a license. You don't need to care about all these things. And depending on how this threshold is defined, well, a lot of projects could be either forced to fully decentralize because they just simply cannot comply with these requirements, or on the other hand, to centralize more because simply, they will be like, okay, I want to interact with institutions.

[00:16:30] Anne-Grace: I want to reassure my users. So the only possible choice is to reach out for a license. So it will be crucial to know how the standard is defined and hopefully it will be a reasonable one. 

[00:16:43] Umar: All right. So just because, DAOs and DeFi have decentralized in their name does not necessarily mean that they will be exempted from MiCA.

[00:16:52] Umar: Now, Anne-Grace, given you worked, for Keom Protocol as well, which is, I'll remind the listeners, a decentralized protocol for lending and borrowing, how have you been interpreting MiCA for the protocol, because this should have been a very hot topic. 

[00:17:08] Anne-Grace: It is, so we are mostly working on how to maybe influence this way of, defining DeFi.

[00:17:15] Anne-Grace: So since for now, there's no clarity. It's up to the industry to push for solutions that are convenient rather than waiting for a solution to come and then just complain about it. This is not the best way to proceed. So we're working a lot on trying to be on a safe side currently, but also just proactively pushing for some new narratives.

[00:17:36] Anne-Grace: Hey, look at DeFi. It can be good. Like, for example, in Switzerland, we have guidelines on tokens. It worked pretty well. It was broad enough. So it gave a lot of leeway in terms of interpretation, but it was like a starting point. Maybe we could have something similar for DeFi.

[00:17:51] Anne-Grace: This is one of the things we advocate for not having specific standards or like specific definitions, but just a starting point that we can work with because otherwise, there's not much that can be done if we don't even have like a couple of words explaining, whether having a centralized, decentralized interface influences, or let's think about admin functions, which admin functions are deemed to be enough control to be centralized potentially.

[00:18:20] Anne-Grace: And for example, you control the custody or you control how, transactions are executed, just having a couple of words there. That then can be refined for practice. That would be useful. So we are only at let's say the policy and lobbying part for now, and as the deadline approaches, and the product we're, working on currently that's not live yet, is being finalized, but then depending on the tendencies we notice by discussing with regulators, we'll just proactively reach out for a license if necessary or, decide that we go even more decentralized.

[00:18:55] Anne-Grace: It's still not decided yet. So let's say I see it firsthand how this uncertainty is, it's not paralyzing, but forces you to act, but without knowing exactly which will be the ultimate action. Do we need a license or not? But in the meantime, there's a lot of moving in all directions and trying just to discuss influence and, hoping for the best, basically, this is where DeFi stands for now.

[00:19:19] Umar: Now, speaking about deadlines, there are two upcoming deadlines to abide by MiCA starting, like I mentioned in the intro starting 30 June, 2024. It's for companies who are issuers of stable coins, but I'd like to skip this category as I believe it's less relevant for the listeners of this podcast and rather focus on the second deadline, which is the 30th of December, 2024, which is for crypto asset service providers, or short for CASP. Now, Anne-Lorinne you wrote a great article, on getting ready for MiCA and I'll actually be sharing the link to the article, in the show notes of the podcast. If someone had like, six months ahead of them to prepare and comply with MiCA, how should they start? And if you could maybe dissect some elements of that article for the listeners. 

[00:20:17] Anne-Lorinne: Yes, of course, with great pleasure. I think the first element you could start with will be actually to have like a health check, like of a business. So you start like by having, so you could actually read this article first.

[00:20:31] Anne-Lorinne: And actually, when the listener will have a look at it, there is sort of a chart which actually leads you to whether you fall under MiCA or not. And this is very, easy to do. And I think this kind of audit actually is quite crucial because you could already have an idea of what kind of services you will be providing or not, and what will be actually your future obligation.

[00:20:55] Anne-Lorinne: And sure, of course, then consulting professional and having help will be essential at some point, but I think doing this preliminary self assessment is really valuable because people are the ones who know their business the best. So next I will actually check out, if you can benefit from the grandfathering rule. Actually under MiCA, EU member states, had the possibility to allow their crypto companies to have sort of a transitional period up to 1st of July, 2026.

[00:21:31] Anne-Lorinne: But as I said, it is like an option. So some EU member states are not going to offer this transitional period, and some other are going to shorten it. So, for example, we already know that Lithuania is not going to have any transitional period. And we also know that ESMA actually called, in late October the EU member state to shorten actually this transitional period to 12 months, 

[00:21:56] Anne-Lorinne: This means that if you're a cap and you are up and running under the national law under your EU member states by the end of the year then it means that you can still actually operate your business.

[00:22:08] Anne-Lorinne: There is no show stopper And you just need actually to and you have some times actually to become MiCA compliant and to apply for the MiCA license, which is actually very interesting because there is usually a gap between like the national law and the MiCA, requirements. 

[00:22:25] Anne-Lorinne: And then actually like the, the final, step, which is always easy to say, but harder like to do is like just to take up action and like to start preparing your application either on the national law to benefit from this grandfathering rule, or if there is nothing that's happening, like to start actually, your application to be MiCA compliant. 

[00:22:46] Umar: All right, so you suggest the listeners should be verifying their jurisdiction to see whether this grandfathering rule, which is the transitional period for MiCA to, apply to them.

[00:22:58] Anne-Lorinne: The problem is it's not that easy to check because only a few EU member states have like already, let's say, gathered the courage to say we do it, we don't do it, or we shorten it. But you can, if there is like nothing that can be found and that's where actually you can actually consult like professionals in the field, if nothing has been said, you can always start by saying, okay, let's assume my EU member states. Nothing has been said that is going against it. So let's take like this secure position that it will only be a year. And so I just have an additional year to be compliant and not like 18 months. 

[00:23:38] Anne-Grace: This reminds me there's maybe another check because you mentioned this yes or no, the entire flow just to have some introspection as a project.

[00:23:46] Anne-Grace: Maybe another thing to have some introspection on is what is our level of decentralization and do we need to care about MiCA first, because so there is, there's a lot of elements to consider, and, as we discussed earlier, a lot of projects are somewhere in between, or they are at an initial stage, and they want to decentralize at the second stage, but the second stage could be in five months or maybe in one year or two years, right? We don't know. 

[00:24:11] Anne-Grace: So it's also just assessing the risk. What is the risk that they may need to comply with MiCA simply because they take too long to decentralize or they will never be able to decentralize enough or the decentralization they contemplated for the project is only minimal because they simply wanted to reach out the community but not that much for the remaining.

[00:24:34] Anne-Grace: So maybe just also check who am I exactly when I'm facing MiCA and then see whether, 

[00:24:41] Anne-Lorinne: Yeah, definitely right, but then, you really need like to be true to yourself and consider that, no, but I'm decentralized. Yeah, but actually you have the button like to unplug everything. Yeah, yeah, but I'm still decentralized, so it's maybe like an external opinion than here on this aspect of someone who could really tell you, you know, under law, you're not decentralized.

[00:25:05] Anne-Lorinne: And because on top of it, I really think MiCA is going to be very, very strict about decentralization. Because maybe I'm a bit too pessimistic, but I think, the European Authority don't really believe in decentralization, like fully decentralized. Okay, so we share the opinion, so it's perfect.

[00:25:24] Anne-Grace: But the discussions you have with people involved with the Commission or the Parliament, like a financial experiment that is very good, but the experiments are supposed to be in the playground somewhere on the side, not handling billions, basically, it's, uh, it's not a problem because it's very contained and you only have the degens using it, right?

[00:25:43] Anne-Grace: You don't have, I don't have my neighbors using DeFi. They probably wouldn't even know where to click first. But as you said, also it's, you need to be honest about it. But it's also also going beyond the vision you're selling. Some people believe so hard vision that it's hard for them to step back and think about what exactly am I doing.

[00:26:03] Anne-Grace: And then even if they reach out to a lawyer, the information they provide does not exactly add up with what they are doing. 

[00:26:10] Anne-Grace: And it's not funny in practice.

[00:26:13] Anne-Lorinne: Completely. And that's, I think it's not a bad thing, actually, that they, you know, that they have a thought about, okay, even like if they are selling, you know, their, their product or vision to someone, I think it's always a good sign as a good sign, even for investor to tell them, hey, we are not like playing dead on this aspect, like we are addressing it.

[00:26:31] Anne-Lorinne: And we have like either, an answer, which says, yes, we have to deal with it or no, it's fine. We are off the hook. And I think it's not like a, like a question you should be ashamed of asking of, or showing to your investor. 

[00:26:45] Anne-Grace: It's also about the growth because many projects don't care about regulators to start with, but they do care about growth.

[00:26:52] Anne-Grace: And if you want to onboard users, you don't want to offer them a product that could be shut down because they receive a notice in the upcoming months. So you want to offer a sustainable product. So if someone doesn't care about regulatory aspects, you can always tell them, but do you want to grow and acquire new users and retain the users you have?

[00:27:12] Anne-Grace: Or do you want to scare them off potentially? 

[00:27:15] Anne-Lorinne: Exactly. That's a really good point. 

[00:27:17] Umar: Before we continue, we'll take a quick commercial break from our sponsor.

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[00:28:59] Umar: Yeah, and that's a good segue into my next question, because we don't want MiCA to be a regulatory burden for these smaller and very innovative companies. So, maybe I want to go through how MiCA compares to the current digital assets regulation.

[00:29:17] Umar: And like I mentioned in the intro, MME is based in Switzerland. So we can compare and contrast with the Switzerland regulatory model, which is often seen as very flexible and business friendly. while MiCA on the other hand is more prescriptive with detailed rules and requirements for different types of crypto assets which can add to more complexity.

[00:29:41] Umar: So how does MiCA's approach to crypto regulation compare to the current Switzerland model? Is one approach better than the other? 

[00:29:51] Anne-Grace: Better, I don't know. We'll see with time, right? Time will show which one is preferred and which one, works better but there's a pragmatic difference is that in one case, the Swiss regulator rated this approach of adjusting existing financial regulations just to take into account the existence of financial instruments on chain.

[00:30:13] Anne-Grace: And then for the remaining, they published very early on guidelines on how to categorize tokens based on the functionalities. And if the functionality is merely providing access to a digital asset or service on chain, being this nice category of utility tokens that everyone wants to fit in, why do they want to fit in this category?

[00:30:35] Anne-Grace: Well, in Switzerland, for example, this kind of tokens are kind of left aside from regulations. You don't need to conduct extensive KYCs. You are not necessarily subject to any banking regulations because even if you keep those assets under custody, you are not regulated. If you advise investments in this kind of assets, because they are not financial instruments.

[00:30:58] Anne-Grace: If they are structured correctly, and they're really have this functionality of merely providing access to, for example, some of your protocol features. So this is this nice, not lenient, but let's say pragmatic approach of if it's not a financial instrument, we will not bring it under, the realm of financial regulations.

[00:31:18] Anne-Grace: In the EU, the approach is more saying we have crypto assets as this broad category. We have tokens and we have crypto assets. Some of them are used as means of payments. Other are potentially financial instruments. Let's say, leave them to MiFID and traditional regulations. But even if it's a utility token, it's considered that there needs to be some clarity on how do we issue them?

[00:31:40] Anne-Grace: Do we need some information? If, some services are provided in relation to them, we still need some regulations, Are also costs if they just touch only utility tokens. And so, for example, an advisor or like some other activities that only, for example, interact with utility tokens will still need to be regulated under the EU standards.

[00:32:01] Anne-Grace: While in Switzerland, there would be potentially outside. And probably, Anne-Lorinne, you can jump to complete that, any other thoughts on this approach? 

[00:32:10] Anne-Lorinne: I think first of all, the main difference between how the Swiss guidelines were drafted and MiCA was drafted is first of all, MiCA was drafted completely during like the episode with Libra with Facebook.

[00:32:25] Anne-Lorinne: And we can see, for example, with everything which is happening with the stable coin that this was really an answer like to protect European monetary sovereignty. First of all, rather than really offering a framework for innovation and actually to foster innovation for my two cents, really. And on the other hand, to be also kind on MiCA, the thing is that MiCA it's the regulation.

[00:32:51] Anne-Lorinne: So it means going to apply to every EU member states equally without having any room like to have some other, adaptation. And the thing is, for example, like the thin line between what is a crypto asset and what, and what is a financial asset, this is actually where it's going to be. people are actually waiting for ESMA and EBA to really provide way more detail than which has been done until now because ESMA has actually published something about that. 

[00:33:18] Anne-Lorinne: And the thing that you have this distinction between MiFID being a directive and MiCA being a regulation can lead actually to, legal uncertainty. And some project could actually be forced to ask multiple regulator in the end if ESMA doesn't provide way more information on that, whether or not their crypto asset is considered, like a financial instrument.

[00:33:42] Anne-Lorinne: So that's also like the whole difficulty about MiCA is it's trying like to set up a rule for 28 member states whereas Switzerland is way smaller. So I think it's also, it was a good intention, it was a good start, but we will still need like to have a lot of talking with the regulators in the future in order really to, set up a real clear set of rules.

[00:34:04] Anne-Grace: I think you said something super important is the context, you reminded it because you can clearly see how it's not supposed to foster innovation because, and we discussed it in the past, there is no sandbox, for example, meaning from the beginning, if you have a project, those activities qualify as services provided with crypto assets.

[00:34:25] Anne-Grace: So if they fall under the CASP definition, well, they need to spend a lot of money to get that license on legal, the whole process, to comply with the requirements. So sometimes you have, an early stage projects that hasn't even checked whether they have product market fits. So they're in the experimenting phase, but they cannot start because they need a license in the first place.

[00:34:49] Anne-Grace: At least there will not be able to start because they will need that license. And in Switzerland, there are probably more options by really starting, for example, just with utility tokens, like cutting some aspects of the project off just to have, like, an initial iteration of a project that does not fall on the regulations.

[00:35:07] Anne-Grace: And here you have, like, a major, difference, I'd say, because MiCA is supposed to protect, but to protect as many users as possible because we had that context that Anne-Lorinne pointed out a lot of failures were out there in the space and everyone's afraid. 

[00:35:23] Anne-Lorinne: You're completely right. Like the protection is very, very important because even EU law is very well known, like to have like this consumer protection at the heart, you know, like really like trying to protect the people, protect the customer. And I think that bad timing for MiCA, but it was drafted when FTX happened and when Celsius happened. And FTX was really like a big, big, event, like, because it really touched a lot of customer here. So, I think the lawmaker had no other choice, but to also be harsh and say, okay, we are going to protect them because, otherwise nothing is going to be done actually by this from themselves.

[00:36:03] Anne-Lorinne: So that's also something I'm completely agree with you Anne-Grace. 

[00:36:06] Umar: Now for the listeners, Anne-Lorinne mentioned ESMA. So, ESMA actually means the European Securities and Markets Authority and is the body responsible to draft MiCA. 

[00:36:19] Anne-Lorinne: I'm just so sorry, Umar, to draft actually the guidelines because it's the European Parliament who dropped the guidelines.

[00:36:25] Anne-Lorinne: So sorry, it's the lawyer in me. So sorry. It's the European Parliament who drafted the law, but then actually the EBA, so like which is the European Banking Authority, and ESMA, so the European Security Market Authority, to work together and have authority to actually draft a technical standard and guidelines, which actually give like more substance to the skeleton, which is actually MiCA.

[00:36:51] Umar: Perfect. Well, thanks a lot for correcting me.

[00:36:54] Anne-Lorinne: No, no, so sorry. 

[00:36:56] Umar: Absolutely not. Absolutely not.

[00:37:04] Umar: I want to touch on the passporting feature of MiCA before, speaking a little bit more about what you guys do at MME. So, the passporting feature for the listeners, it is a feature of MiCA designed to facilitate the provision of crypto asset services across the EU.

[00:37:20] Umar: So let's say I'm based in France and I want to provide my services in Portugal, I won't need to obtain like separate authorizations from Portugal. Now, I want to touch on the obligations of service providers outside the EU, if they wish to offer their services within the EU. So let's say I'm a US company, but I do fall under the definition of crypto assets service providers.

[00:37:47] Umar: What would be my obligations to then comply with MiCA? 

[00:37:51] Anne-Lorinne: So if you're a US company, and you cannot rely on reverse solicitation, but that's something I think we're going to address later on, you will need a license basically as I explained earlier, and you will need actually to operate within the EU.

[00:38:06] Anne-Lorinne: And this isn't just, you know, filing paperwork, obtaining just your license. And meeting the prudential requirements. It means also like establishing some real presence in the EU. So the company will have like to register an office in the EU. So you can choose the EU member states you wish. And from this EU member state, the US company will have actually to conduct some of his business. It cannot be like an empty shell and effective management of the company must be from this EU member. So actually there are the consequences are not that light for a US company. They will really need like to do some additional work.

[00:38:47] Anne-Lorinne: And now the big question actually, and only time actually will tell us is how effectively EU authorities can track down and enforce, you know, MiCA against foreign crypto companies who will target EU customer without having the proper license and without having any, you know, sort of entity or something like the European authority could have a hand on.

[00:39:12] Anne-Lorinne: So this part actually of the puzzle will heavily depend on international cooperation between regulators.

[00:39:19] Anne-Lorinne: And we will only know tomorrow how, I don't know, for example, EU send the SEC or, any other international regulators who actually work together in order like to achieve consumer protection. 

[00:39:34] Anne-Lorinne: And this cooperation actually will heavily depend on political issues and the political game between the countries to actually win the competition race, you know, between who is going to be the most competitive and who is going to create the most interesting framework for a crypto company to come and like establish their business.

[00:39:54] Umar: All right. And there is, an exemption as well called the reversal, solicitation exemption exactly where companies outside the EU would not need to obtain prior authorizations. What are some of the conditions briefly to apply for this exemption? 

[00:40:10] Anne-Grace: I mean, nowadays we can say, it's a very narrow one.

[00:40:14] Anne-Grace: The idea is to be just logical. If you don't operate in the EU because you're not even targeting them. And a user let's say from Belgium decides to reach out for your services, well, it shouldn't force you to reach out for a license just because that's one person. Figure it out that you have a great landing page and they just by browsing on Google ended up on your web page, this is not the goal. 

[00:40:39] Anne-Grace: But then if you start actively targeting those users, and there are many ways in which you can target them. And this is where the problem will start is which targeting, actions are enough for the regulator to say, hey, you actually should get a license in the EU. And why did I start by saying it's narrow?

[00:41:00] Anne-Grace: Because as we've seen in practice with MiFID and interpretation will not be that different for MiCA, you don't need that much. So if you expressly translate your entire website, all of a sudden in Greek, well, it gives a hint that potentially you want to have Greek users. And then if you look into how web3 is marketing, which is quite different.

[00:41:22] Anne-Grace: I mean, you don't in some in Switzerland, you could, we could see some crypto advertisement on tramways in the streets or at the airport. Like one of the first things you see when you land in Switzerland, this is one of those ads that be that the Geneva or Zurich airport, you could have companies deciding to do the same in the EU member states.

[00:41:39] Anne-Grace: This is quite obvious. But then there are less obvious cases such as what if I show up at ETHcc in France or in Brussels this year, and then have a speech there, hand out merch? Does that count as targeting the local crowd? And this kind of things, or what if I am all of a sudden contracting with a KOL from a specific country?

[00:42:00] Anne-Grace: Like all of a sudden needs an influencer from Finland, or I take an influencer from Poland. Doesn't mean I'm targeting Poland. So there's very pragmatic elements are there. And I mean, Twitter gave us the first case. The BaFin was quick to react. Adding a hello Deutschland with a German flag is enough to react.

[00:42:20] Anne-Grace: So be very cautious with the emojis you use and try to avoid flags. This is a very good starting point. I mean, other jurisdictions have told us that we should also avoid rockets and other elements hinting on financial advice in the EU. It's more avoid flags, at least any flags related to the EU and the European flag itself.

[00:42:39] Anne-Grace: But all these additional things that we do in web3, as soon as they create some sort of more obvious jurisdiction, could be deemed as going against the possibility of relying on reverse solicitation. Then the question is, how will it be in practice? Like, what are the tools that all these national authorities will have to detect this kind of things and to actually go against them and just send a nice letter to one of these projects and say hey, you are actually targeting our jurisdiction.

[00:43:10] Anne-Grace: We don't know yet. So we'll see in practice, we have always this safe side. Let's consider it's a very narrow exception. And as soon as you have any marketing efforts targeting even in a small way, or at least what seems a small way the EU market, we cannot rely on it. And then there's like the more, less cautious way of saying, hey, this is too small.

[00:43:31] Anne-Grace: No one will pay attention. I would not recommend that path. But we, we need to be pragmatic. Potentially indeed, the regulator will not be told enough to react to everything, but never underestimate the regulator. They may surprise us. 

[00:43:46] Umar: At first glance for someone who's not, let's say following everything with MiCA, at first glance, this seems to be a barrier to bring these, innovative web3 startups into the EU.

[00:43:59] Umar: Now, what I want to ask you Anne-Lorinne and Anne-Grace, from what you've been observing, is there one particular jurisdiction that maybe a lot of these non EU startups have been flocking to? 

[00:44:12] Anne-Lorinne: The eastern EU member states have had like a great number of license and of, registration. Like Lithuania actually was one of which who had like a really, really high number of license given out because it has actually this very easy set up. But for example, you also have France, France also has managed like to, attract very, very interesting, project.

[00:44:35] Anne-Lorinne: You can see also that there was some split between like the specialty of a project, who is going where. 

[00:44:42] Anne-Lorinne: For example, I think France has a really good knowledge with everything which is related to NFT gaming and the Eastern European member states have like good, protocols and good, DeFi or financial, project. 

[00:44:55] Anne-Lorinne: I think you go actually to the EU member states where like the founders are from, or if you are like aware that the regulator already has like a solid legal framework, which was actually the case of France in the beginning, because with the Loi PACTE, it was a novelty and they were actually the first one to do it.

[00:45:13] Anne-Lorinne: And MiCA is actually inspired by this law. So yeah, I think we are actually witnessing a very interesting period of time because, this grandfathering rule is also going a bit to reshuffle, where companies used to go, because depending on if you will have or not additional time to be MiCA compliant, I think it will definitely have an impact where, either new starter will be established, but also like the old ones where they will maybe set up another subsidiary in order actually to benefit from the grandfathering role in somewhere else. 

[00:45:48] Anne-Grace: The first one I think is France, just because of the framework. Now Poland wants to attract a lot of, they see it as an opportunity, they made a couple of statements and there's a lot of projects, with Polish developers and it's like a whole ecosystem.

[00:46:02] Anne-Grace: I have ETH Warsaw, a lot of very exciting projects based there, so I'm curious how this will go. And there's a, a nice saying in Polish which can be translated to when a Polish person wants to, they will manage to achieve it. So it can become an interesting jurisdiction. And, Liechtenstein, because they always want to attract people.

[00:46:23] Anne-Grace: Plus for all the projects, active in Switzerland this can be a nice entry to the EU markets by not going too far and still interacting with a jurisdiction that is very close. 

[00:46:35] Anne-Grace: Thinking about Germany, because we always mention the BaFin for the how strict they are and how everyone fears BaFin, especially like anyone who has a fintech, like more web2 fintech background, like when you mentioned BaFin to them, or like the couple of projects that's obtained a BaFin license for a web3 project.

[00:46:53] Anne-Grace: You can sense the trauma, but BaFin has a lot of knowledge and they, they are really good on some points as well. They organize like events on DeFi. So there is a curiosity and there's an interest into really getting into the space and understanding this project. So this could be a very interesting jurisdiction too, depending on how things evolve. So yeah, I'm forward looking. I see hope out there on the horizon.

[00:47:19] Umar: I think it's time we speak a little bit more about MME and the services you provide. So like I mentioned in the intro for the listeners, MME is a firm based in Switzerland offering law, tax and compliance services for a lot of different industries, but also for the web3 industry, as a whole.

[00:47:39] Umar: Now let's see, I'm at a company. looking at the new regulatory requirements and the MiCA and we walk through today how complex some of these requirements can be. And, this is currently proving to be a very burdensome for me. How can MME assist me today to be MiCA ready? 

[00:48:03] Anne-Grace: If you reach out to MME, the first thing would be that you potentially already are set up in Switzerland or consider starting from Switzerland, right? But then, obviously, for all the reasons we mentioned, including how solicitation rule will be applied.

[00:48:19] Anne-Grace: If you know you want to not be limited in how you market to the EU user base, you'll ask us, what can we do about MiCA? Well, luckily for you, you have Anne-Lorinne and me, so double Anne problem there. With the EU background, so, Anne-Lorinne, had the chance to analyze, like, all those, all potential overlaps and what are the differences between the frameworks, so we can always optimize the setup to make sure that you don't need to go through the entire pain of reviewing the setup twice, basically, where you have a Swiss setup that can work also from a EU perspective, and then, simply put you in touch with the right people for the licensing process, if necessary, from EU perspective, so have a smooth process where you don't need to do the same work twice. 

[00:49:06] Anne-Grace: Because it could be that you have a great setup in one jurisdiction outside of the EU, but it doesn't work at all from a EU perspective, and you would need to adjust it, but then potentially it doesn't work from that initial perspective anymore. Well, here we have both lenses, we can work out a solution, having all the constraints in mind, and making it a smooth process at the end.

[00:49:31] Anne-Grace: Anne-Lorinne if you, you want to jump on that. 

[00:49:35] Anne-Lorinne: It's very hard to  follow such a really great speech, but, I think also what would be very interesting is that Switzerland always had like, as Anne-Grace pointed out, this privileged relationship with Liechtenstein. And like Lichtenstein is actually a way for us like to get into the European market.

[00:49:52] Anne-Lorinne: And so we are actually establishing like a real close relationship and like starting very interesting discussion in order actually to build up a system which could work and how we could actually really also advise our clients in a way, like to have like a sort of key solution where we can explain to you.

[00:50:11] Anne-Lorinne: Okay. That's what's going to happen to you and this is actually the next step that we advise you could go through and you can go actually to this or this jurisdiction and you will be well served and you will have all the answer that you need 

[00:50:24] Umar: Perfect. Now in addition to MiCA compliance, MME does offer a range of services.

[00:50:31] Umar: So could you share a little bit more about these other services? And given that this podcast is listened again by many accountants and CFOs, is there a particular service that is frequently sought after from, people in such functions? 

[00:50:48] Anne-Lorinne: So that's my turn, I assume, Anne Grace. 

[00:50:51] Anne-Grace: In my mind it's tax.

[00:50:54] Anne-Lorinne: That's true, tax.. And also, so it's not exactly tax, but usually CFO or accounting also must have a look at the services, which is also all this AML compliance to really understand whether the onboarding of the client who they are actually onboarding.

[00:51:09] Anne-Lorinne: And that's actually something MME does support with. And yes, as Anne-Grace say, I think accountant and CFO really value any collaboration they can have with MME tax team, because our tax team is very, it also have a special relationship and very privileged relationship with for example, the canton of Zug, who is actually excelling in like offering solution for crypto companies and who really managed like to have tailored made solution for them. And these, tax authority have usually like a good knowledge also of what these companies, do and we are able to answer actually, as Anne Grace pointed out in the beginning, like if it's a shark or a little fish, how should it be shown on your balance sheet, whether the tax authority would agree with it, how you would actually structure your, pricing between like your different transfer price, tax issue.

[00:52:06] Anne-Grace: So I think that's, yeah, that's the two main services, which are usually very, very, attractive, but of course, which are also the last aspect, I think, which is very interesting is that the, Tax, the tax team also works hand in gloves with the regulatory team, and so. You mentioned something that's extremely precious actually at the end of the day, by saying that there's like this privileged relationship with the Canton of Zug. But just in general, because of how many cases were handled to develop relationships, you know, which authorities react in which way, and be it service providers and the right cantons that speak the same language. so it's a very complex project, with very like difficult text questions. You may not want necessarily to direct it to some authorities where you would really have a hard time explaining what exactly happens there. So you need to find the right people to interact with and if necessary, do some translation job there.

[00:53:02] Anne-Grace: How do we translate web3, for the authorities for them to understand, what is happening there? And all these services also interact, greatly like with our team for regulatory aspects because often this translation involves figuring out the regulations, the qualification of the token, and this kind of aspect.

[00:53:21] Anne-Grace: So this translation is accurate. Which is important. It's like the basics, the first step of the process before you can go further. 

[00:53:29] Umar: Anne-Grace and Anne-Lorinne, I'm seeing the time pass by and I want to be respectful of your time. Maybe I have a last question for Anne Grace. I saw you participated at ETH Prague last week on, and you participated in a panel on how to make DeFi accessible for everyone.

[00:53:47] Umar: Now, we spoke extensively of MiCA today. If you had to share with the listeners, some of the ideas brought forward during your panel at ETH Prague, what would those be? 

[00:54:00] Anne-Grace: Okay, so a very quick summary. The first point is quite obvious, DeFi is complicated. So most people will simply not interact with it because.

[00:54:09] Anne-Grace: They wouldn't know where to click, first of all, they wouldn't see what's in it for them. If you show a landing protocol to anyone in the street, they will first ask, why would I even use that? Because of how we present DeFi, we often put forward things like points, quests, getting more yield and this kind of things.

[00:54:29] Anne-Grace: But it's, we need to translate it for real life use cases. If I have a co housing project, can I, somehow try to get liquidity through a lending protocol, or can I only, consider traditional loans? If I am someone who doesn't have access to traditional banking systems, can I utilize the lending protocol to supply liquidity and have it as an alternative to a bank account?

[00:54:56] Anne-Grace: Can I stake or utilize some of the other protocols for trading to generate some sort of, interest in a more, let's say, riskier way, but still by understanding the risk of simply having a different way of presenting the service for users to understand what they can get out of it. Users not being crypto savvy users and degen users who know pretty well what they can get out of it.

[00:55:19] Anne-Grace: But the second major aspect was risk, and having a responsible DeFi approach. Cause for now, one of the questions that you may ask us, why would I deposit funds into one of these protocols instead of keeping them on my non custodial wallets and simply waiting for the prices to go up? Because in the first case of the protocol, I could lose it all because of an economic exploit, because maybe, there'll be like a rug pull or simply the protocol had the backdoor and the founders will just take all of it away.

[00:55:50] Anne-Grace: I mean, there's a lot of things that could happen. So there is a bigger risk by putting this funds out there and simply keeping them on a non custodial wallet where risk zero doesn't exist either because there are phishing attempts and so on. 

[00:56:03] Anne-Grace: But how do we tackle risk by knowing that a user base being more retail wants to understand the risk and will not utilize a project that is basically dangerous. And for people who simply cannot access other types of products because they don't have access to it or because simply they're excluded for the financial system. How can we make it still a reasonable solution?

[00:56:27] Anne-Grace: If I don't have many savings because I live in a small village somewhere, but I still have access to web3, I may not want to use nevertheless web3 if I risk losing the small savings I have, right? And then I mentioned having a responsible, responsible approach to DeFi. Well, currently DeFi believes it's not regulated.

[00:56:47] Anne-Grace: Be it's correct or not, we'll see with time. But because it's not regulated, it does not really implement many, standards in terms of quality. So you have technical standards and they excel at it. You have great technical audits, a lot of improvement there, very exciting new technologies, but what in terms of like best execution, preventing market manipulations, having some sort of reserve standards, some insurance and very traditional aspects that would be a transposition of what we know in traditional financial regulations.

[00:57:20] Anne-Grace: It's not because it's in the regulations that it's bad, and it should be set aside. Regulations are nothing more than a tested recipe on how to bake a good financial service. And you may not want to implement it the same way. You may consider it's just stringent, not all of it is relevant, but taking some of these spices and putting them into DeFi would probably be the best way to go forward.

[00:57:45] Anne-Grace: To provide better services also boosted up because they don't want to use something that might bite you back. I always say that for now, DeFi is basically this, beach where no one is, there to save you if you drown, but there's also no one to tell you that you're, you're not supposed to be on that beach or that you're doing something that's stupid. 

[00:58:05] Anne-Grace: So that second part is nice. The first one is less nice because we're kind of used to having some sort of safeguard or someone who can just pop out and say, Hey, I'm going to give you a helpful hand, which you don't have in DeFi. So we'll see how it evolves, 

[00:58:18] Umar: Thanks for sharing. As closing thoughts, Anne-Grace and Anne-Lorinne, uh, has there been any anything else today that maybe we didn't go through or to wrap up the episode, would you like to summarize like the very essential, points for the listeners about getting MiCA ready 

[00:58:37] Anne-Grace: Maybe get some thoughts on that, but I have one sentence wrapping it up. Don't fear MiCA.

[00:58:43] Anne-Lorinne: Yes, so don't fear MiCA. Try to have this preliminary assessment. Try to understand what could be your obligation in the future. And just like reach out for any help if you need any, because you cannot like hide from it anymore and you have to do something about it. 

[00:59:03] Anne-Grace: You can't pretend it's not there. These days are over.

[00:59:07] Umar: Now there's the last question, which I like asking to my guests before they leave is, do you have a favorite quote or a maxim, let's say that you live by? 

[00:59:16] Anne-Lorinne: That's, that's always a very interesting thing. There is a saying that I like, which is, it is extremely rare for a mountain to be steep on all sides.

[00:59:26] Anne-Lorinne: So it shows that actually, like, I think it's a message of hope for DeFi and even crypto projects in general, because we are creating the future and like any demanding project, it takes time and when it doesn't work one way, Just choose another way. And also it's a personal reminder when I stumble upon an obstacle just to take another angle, because I think in life, everything is about angles.

[00:59:54] Anne-Grace: It's funny because you have the message of hope and I've been like mentioning DeFi several times, throughout this last hour, but I'll have maybe, uh, Less hopeful, but, more, down to earth and, uh, teaching like style, a quote It's not a quota that I live by, but it's more a quote I think it's quite relevant, in the web3 space.

[01:00:14] Anne-Grace: being that with great wealth comes great responsibility. So we're used to, with great power, wealth is power and it's also responsibility. And I think we tend to forget it sometimes because it's all on chain. It's all transparent. It's just tokens. And it feels like a big game, to some builders in the space, which yes, web3 is fun, but because of the initial objectives, which were so like financial inclusion, trying to create this alternative financial system, there is wealth there and wealth being handled and we cannot do it as if it was just a game. We need to be responsible about it, and have a specific approach to show the world that it's not just a bunch of people, building tools that no one cares about, but actually we're building the future.

[01:01:01] Anne-Grace: We need to be, um, I can't find my word here. 

[01:01:05] Umar: Legitimate.

[01:01:06] Anne-Grace: Legitimate, that's better. if Web3 tools wants to look legit The traditional sector and to a massive user base beyond people who are already convinced by crypto they need to take this responsibility aspect into account 

[01:01:21] Umar: Perfect. Well, Anne-Lorinne and Anne-Grace. Thanks a lot for your time today.

[01:01:26] Umar: Thanks for being so generous with your . I learned a great deal about MiCA just by preparing this episode. I'm sure the listeners did as well. Before going if people want to possibly reach out to you and get in touch with you for MiCA or any of the legal and tax services that MME provides, how should they do so?

[01:01:47] Anne-Grace: Website is the best way I think, you can submit your requests. 

[01:01:52] Umar: Perfect. So at mme.ch. 

[01:01:55] Anne-Lorinne: Exactly. And there is our email address where if you search in the team, like you will find Anne-Grace and myself, and you can always very happy to, like answer any questions if you have any.

[01:02:06] Anne-Grace: If the website is not enough, you prefer like some, a human face, send an email, just send us an email. 

[01:02:15] Umar: Perfect. Well, thanks a lot again. And we'll be in touch. Thanks a lot 

[01:02:19] Anne-Lorinne: for the invitation. Right. Thanks a lot. 

[01:02:21] Anne-Grace: It was a pleasure. 

[01:02:22] Umar: I would like to thank everyone for listening to this episode. You will find all the links of the episode, show notes, and transcript on the website of The Accountant Quits at theaccountantquits. com. 

[01:02:33] Umar: Please note that this content is for general information purposes only and is not a substitute for consultation with professional advisors. If you do know anyone who could benefit from the episode and you care about them, please do share the episode with them. All the episodes are available on Spotify, Apple Podcasts and Google Podcasts.

[01:02:53] Umar: And by leaving us a review and rating, you will support the channel and all your fellow accountants. In order to be notified each time we release a new episode, do follow us on Instagram and LinkedIn. We hope to have you with us next time. Bye for now.