Working with EU partners - aligning with MiCA expectations from day one

You don’t need an EU address to start speaking MiCA. If you want European partners to take you seriously, show that your product, controls, and documentation are already aligned with how EU crypto-asset service providers are assessed. Whether you’re pursuing a crypto license in bosnia and herzegovina or operating from any other non-EU base, this article gives a simple, practical path you can execute in days, not months.

Who this is for

Founders and compliance leads at non-EU crypto firms planning to work with EU exchanges, brokers, fintechs, banks, or payment companies.

Why MiCA matters in partner due diligence

Even if you won’t offer services directly in the EU, your EU counterparty will vet you against MiCA-style expectations. They care about:

• Clear token and product classifications.
• User disclosures and complaint handling.
• AML and Travel Rule readiness.
• Governance, outsourcing, and incident management.
• Data protection and record keeping.

Step 1: map your product and tokens

Start by labeling what you have and what you don’t.

• What services do you provide: exchange, brokerage, custody, advice, portfolio management, order execution, or a purely technical service.
• What assets are in scope: payment-like tokens, asset-referenced tokens, e-money styled tokens, utility tokens, or NFTs that behave like financial instruments.
• What you do not do: lending, leverage, derivatives on crypto, or anything that triggers separate licensing in a partner’s country.

Deliverable: a 1-page product and token map in plain English. Partners need to understand your perimeter fast.

Step 2: write user disclosures that actually help

EU partners will expect user-facing information that is accurate, accessible, and non-promotional.

• Plain-language risk warnings that reflect the real risks of your service.
• Fees and charges laid out upfront, with examples.
• Conflict of interest statement: how you avoid trading against users.
• Complaints policy with response times and escalation to an independent body where available.

Deliverable: 3 short documents - Terms of Service summary, Risk Summary, and Complaints Policy - ready to link in-app.

Step 3: build a lightweight governance pack

MiCA expects clear responsibility, even at small firms.

• Name an accountable person for compliance and risk.
• Create a responsibilities matrix for founders and leads.
• Document outsourcing: who does what, how you supervise vendors, and exit plans.
• Business continuity basics: backups, key rotations, emergency communications, and RTO/RPO targets you can actually meet.

Deliverable: a 6-8 page Governance & Outsourcing memo your partner can file.

Step 4: AML and Travel Rule from day one

EU partners will not onboard if your AML is theoretical.

• KYC you can run today: risk-based tiers, PEP and sanctions screening, proof-of-life checks where relevant.
• Source-of-funds questions that change with risk level.
• Wallet provenance: basic blockchain analytics rules for deposits and withdrawals.
• Travel Rule: name the provider, show message formats you support, and define a fallback for counterparty-not-found.
• SAR/STR triggers and an internal escalation pathway.

Deliverable: a concise AML Program with a 1-page control matrix mapping risks to controls.

Step 5: custody and safekeeping that pass a sniff test

Even without a full custody license, partners expect to see how you keep keys and user assets safe.

• Key management split by role and environment.
• Hot-warm-cold wallet policy and movement thresholds.
• Daily reconciliation against the ledger and exception handling.
• Independent access logs and tamper-evident monitoring.

Deliverable: a Custody & Reconciliation playbook your engineering team actually follows.

Step 6: incident response and reporting

EU partners ask how you handle bad days.

• Severity levels and who declares an incident.
• 24- or 72-hour notification timers to partners and users, where applicable.
• Forensics plan that preserves logs and device images.
• Post-incident review with assigned remediation.

Deliverable: a 2-page Incident Response plan with a contact tree and communication templates.

Step 7: data protection and records

You don’t need to be an EU controller to respect EU data.

• Keep only what you need, for as long as you need it.
• Maintain an inventory of personal data and processors.
• Cross-border transfers: document your legal basis and safeguards.
• Give users a clear path to access, correction, and deletion where legally possible.

Deliverable: a Data Protection summary plus a Records Retention schedule with real dates.

Contracts EU partners expect to see

Prepare a clean, current set of agreements before diligence starts.

• Service Agreement with scope, uptime targets, audit rights, and termination for regulatory cause.
• Data Processing Agreement, including sub-processor list and security measures.
• Travel Rule and AML cooperation addendum covering information sharing and response times.
• Incident and breach notification clause with timeframes.
• Change management clause for material product changes.

Deliverable: a diligence folder with signed PDFs and redlines ready for legal review.

Red flags that stall partnerships

Avoid these common blockers:

• Vague or promotional token claims with no classification rationale.
• AML controls that rely on manual checks with no audit trail.
• No wallet screening or reconciliation evidence.
• Outsourced critical operations with zero oversight or exit plan.
• Marketing that targets EU users when you have said you won’t service them.

A simple 30-60-90 day roadmap

• Days 1-30: product map, disclosures, AML skeleton, custody basics, governance memo.
• Days 31-60: finalize contracts, Travel Rule integration, incident runbook drill, records schedule.
• Days 61-90: internal audit of controls, fix gaps, prepare partner-ready evidence pack.

Final thought

EU partners don’t expect perfection on day one. They expect clarity, control, and honesty. If you can show how your risks are identified, which controls you run, and how you will keep improving, you’ll clear the MiCA bar that matters most in partnerships: trust.