The licensing process for providers of crypto-asset services is a completely new process in the Czech (and EU) environment. A large number of entities have already applied for a license, and it is not surprising that most of them have encountered their first obstacle in the form of a "Request for Missing Information" from the Czech National Bank.
Such a request means that the CNB has reviewed the application and found deficiencies that need to be remedied within a relatively short period of time. This is a stressful moment for many applicants.
What areas does the regulator often criticize?
In licensing procedures, we repeatedly encounter the following problematic areas:
- The CNB often criticizes business plans for being unclear or too general. It wants to know the specific services, operating model, and realistic financial development.
- Insufficiently described AML processes and risk management are also a problem. The regulator is not satisfied with general phrases; it requires a detailed description of practical procedures and tools.
- A weak organizational structure is another common shortcoming. It is necessary to clearly show who has what responsibilities and to document the expertise of key personnel.
- The regulator also insists on proof of financial security. The applicant must prove that they have real capital, otherwise the application loses credibility.
- New requirements arising from the DORA regulation are also emerging. The CNB expects applicants to submit how they address cybersecurity, system testing, and outsourcing management. Failure to address this area is considered a fundamental deficiency.
How can we help you?
Our office has extensive experience with licensing proceedings before the CNB. Over the years, we have participated in dozens of successfully completed processes. Thanks to this practice, we have a good understanding of what the regulator often focuses on when evaluating applications.
We will help you:
- quickly analyze the content of the request and propose the most appropriate response,
- prepare and supplement the documentation so that it is complete,
- guide you through the entire process efficiently and minimize the risk of further delays.
Obtaining a license is not easy, but with the support of experts (our lawyers and economists), the complex process can be managed without unnecessary delays.
