1. Placement scope
Define the crypto-assets, offeror or issuer relationship, service scope, target jurisdictions, distribution channels, and whether the activity overlaps with other CASP services.
A practical evidence checklist for CASPs involved in placing crypto-assets: placement type, purchase-guarantee assumptions, fees, timing, process, price, targeted purchasers, issuer agreement, and conflicts controls.
Informational only. Not legal, regulatory, brokerage, underwriting, or insurance advice.
Regulation (EU) 2023/1114 Article 79 addresses placing of crypto-assets. A conservative, review-ready evidence pack should show what information the CASP communicates before entering into an agreement: the type of placement, whether a minimum amount of purchase is guaranteed, transaction fees, likely timing, process and price for the proposed operation, and information about targeted purchasers.
This page turns Article 79 into an evidence-preparation checklist. It is not a legal interpretation, placement mandate, offer document, broker recommendation, or regulatory filing guide.
Define the crypto-assets, offeror or issuer relationship, service scope, target jurisdictions, distribution channels, and whether the activity overlaps with other CASP services.
Keep a clear record of the type of placement under consideration, including whether a minimum amount of purchase is guaranteed or not, and who approved that wording.
Document transaction fees, non-monetary incentives, commercial dependencies, pricing assumptions, and the review owner for changes before client or issuer communications go out.
Maintain version-controlled evidence for the likely timing, process and price of the proposed operation, including assumptions, approvals, updates, and unresolved dependencies.
Record how targeted purchasers are described, which client categories are in scope, what suitability or communications controls apply, and how marketing claims are reviewed.
Capture issuer or offeror agreement evidence, then connect the placement file to Article 72 conflicts procedures, Article 66 conduct controls, complaints handling, and operational-risk review.
Article 79 concerns placing of crypto-assets. The operational question is whether the firm can show a reviewable record for the placement type, guarantee assumptions, fees, timing, process, price, targeted purchasers, issuer or offeror agreement, and conflicts controls.
Placing workflows can create conduct, pricing, allocation, disclosure, conflict, complaint, payment, custody, outsourcing, and incident risks. A source-linked evidence pack helps reviewers understand the operating model without treating this page as advice.
No. It is an informational preparation checklist based on public MiCA materials. Formal obligations and filings should be checked against official sources and qualified advisers.