MiCAR Consulting and Regulatory Advisory for the Crypto Sector
Tomato Blue supports crypto-asset operators, fintech and blockchain projects with clear, concrete and growth-oriented regulatory solutions, guiding them through every phase of the MiCAR journey.
We combine regulatory expertise, strategic vision and operational approach, transforming European regulation into a competitive advantage for your business.
1. Strategy and Regulatory Readiness
We start from strategy, translating regulations into operational and sustainable decisions.
What we do:
- Business model analysis against MiCAR regulated services (custody, exchange, advisory, order execution, etc.)
- Identification of regulatory gaps, risks and priorities
- Evaluation between national authorization and European passport
- Support in choosing the most efficient jurisdiction
What you get: A clear regulatory roadmap, aligned with product, timelines and growth objectives.
2. MiCAR Authorization and Licensing
We manage the authorization process end-to-end, acting as regulatory partner and single point of contact with authorities.
Structuring and Pre-Application
- Preparation of corporate and regulatory documentation
- Business plan compliant with MiCAR requirements
- Definition of governance, organizational structure and internal controls
- Planning of capital and own funds requirements
Compliance Framework
- AML/CFT programs compliant with 6AMLD and Travel Rule
- KYC/CDD procedures and transaction monitoring
- Conflict of interest and transparency policies
- Complaints management and internal audit systems
Regulatory and Client-Facing Documentation
- White papers for crypto-asset issuers
- Terms and conditions of services
- Risk disclosures and client documentation
- Pre-contractual and periodic disclosure templates
Technology, ICT and Security
- ICT and cybersecurity assessment in line with DORA
- IT security policies
- Business continuity and disaster recovery
- Evaluation of custody solutions (hot and cold wallet)
Authorization Process Management
- Direct dialogue with CONSOB, Bank of Italy and ESMA
- Submission and management of authorization application
- Management of feedback and supplementary requests
- Support during meetings, hearings and regulatory discussions
Result: a structured, efficient authorization process ready for regulatory engagement.
3. Ongoing Compliance and Regulatory Operations
Authorization is just the beginning. Tomato Blue supports clients in maintaining compliance over time, even during growth.
Ongoing Regulatory Support
- Monitoring of regulatory updates
- Updating internal policies and procedures
- Management of mandatory communications to authorities
Regulatory Reporting
- Preparation and review of periodic reports
- Support on capital and financial indicators
- AML/CFT reporting and suspicious transaction reports
- Communications relating to significant events
Operational and Inspection Support
- Assistance during inspections and audits
- Ongoing MiCAR training for management and team
- Periodic assessments of internal control systems
4. Growth, Expansion and Complex Situations
We support clients in strategic evolution phases, ensuring regulatory continuity.
- Authorization extension (new services or assets)
- European passport and cross-border operations
- M&A transactions with regulatory implications
- Appointment and replacement of corporate officers
- Complaints and regulatory proceedings management
- Advisory on complex interpretative matters
5. Training and Regulatory Enablement
We build solid internal competencies through targeted training programs:
- Training for board and top management
- Operational training for compliance and front-office
- Workshops on regulatory updates
- Inspection and regulatory audit simulations
Why Tomato Blue
- Specialization in MiCAR, AML/CFT and EU crypto regulation
- Practical and business-oriented approach
- Direct experience in dialogue with authorities
- Complete support: from strategy to operations