RE: UAB Micar approved in Lithuania2 Mar 2026 19:09
While UAB Micar Assets may appear to have limited physical substance based on standalone employee data (showing 1 insured person as of early 2026), its approval by the Bank of Lithuania (BoL) is not a result of laxity, but rather its integration into a heavily regulated financial group.
The company passed the stringent MiCA licensing process primarily through the following factors:
1. Backing by a Regulated Entity
The BoL places significant weight on the "fitness and propriety" of shareholders. UAB Micar Assets is majority-owned by UAB FMĮ "Myriad capital", an established Lithuanian financial brokerage firm already holding a Category B license from the BoL.
* Infrastructure Sharing: Under MiCA, entities can leverage the existing compliance, IT, and internal control frameworks of their parent financial institutions, provided they remain accountable.
* Proven Track Record: The regulator is more likely to approve a specialized subsidiary of an existing regulated broker than a standalone startup with no history.
2. Outsourcing and Group Resources
While Micar Assets itself has minimal direct staff, MiCA allows for the outsourcing of critical functions (like IT or AML monitoring) as long as the firm maintains effective oversight.
* Compliance Personnel: The BoL requires a dedicated, resident AML manager. In group structures, this individual often has deep experience and is supported by the parent company's legal and compliance departments.
* Operational Substance: The "substance" is often assessed at the group level, where the actual technical and operational heavy lifting occurs.
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* 3. Capital and Prudential Requirements
Passing the license requires meeting strict capital thresholds—typically €125,000 for services like custody and portfolio management—plus a reserve of 25% of annual fixed overheads.
* As a subsidiary of a brokerage firm, Micar Assets likely demonstrated immediate access to these funds through its parent, satisfying the BoL's liquidity and stability concerns.
4. Narrow Service Scope
The company’s "shell-like" appearance might reflect a very targeted business model (e.g., providing crypto liquidity specifically for Myriad Capital's existing brokerage clients). MiCA requirements are proportionate; a firm with a small, well-defined client base and no retail "public-facing" platform faces different scrutiny than a massive exchange like Robinhood.
Note: The Bank of Lithuania has used the MiCA transition to "cleanse" the market, reducing the number of crypto firms from hundreds down to a handful. Any firm that survived this process, regardless of its size, has undergone an exhaustive audit of its governance, IT security, and AML policies
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