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The Road to Becoming a MiCAR-Regulated Crypto OTC Desk: Challenges and Opportunities

Apr 28 2025

The crypto OTC desk has long played a crucial role in the digital asset ecosystem, offering deep liquidity and personalized service for clients executing large crypto trades outside traditional exchanges. Crypto OTC desks exist to facilitate high volume transactions for traders who require a more customized trading experience compared to traditional exchanges. With the introduction of the Markets in Crypto-Assets Regulation (MiCAR) in Europe, the OTC landscape is entering a new era — one where regulatory compliance will define future success.

For crypto OTC desks aiming to thrive, becoming MiCAR-regulated is both a challenge and a tremendous opportunity. Let’s explore what it takes to get there.

Key Point Summary

Introduction to MiCAR Regulation

The Markets in Crypto-Assets Regulation (MiCAR) represents a significant milestone in the regulation of crypto assets within the European Union. Designed to provide a comprehensive framework, MiCAR aims to address the complexities and risks associated with the rapidly evolving crypto market. This regulation applies to all crypto OTC desks and trading platforms operating within the EU, ensuring a standardized approach to the issuance, trading, and custody of crypto assets, including Bitcoin and other digital assets.

Under MiCAR, any OTC desk or trading platform must obtain a license from the relevant national authorities before commencing operations in the EU. This licensing requirement is a critical step towards fostering a secure and transparent trading environment, protecting investors, and maintaining financial stability. By setting clear guidelines and standards, MiCAR seeks to mitigate risks such as market manipulation and ensure that all market participants adhere to stringent compliance protocols.

Understanding the Role of an OTC Desk

An OTC desk, or over-the-counter desk, serves as a specialized trading platform that facilitates high volume transactions of crypto assets between two parties. Unlike traditional exchanges, OTC desks provide deep liquidity and personalized service, catering primarily to institutional investors and high net worth individuals. These desks enable buyers and sellers to trade large amounts of crypto assets discreetly, without causing significant market price fluctuations.

OTC trading is particularly advantageous for those looking to execute large crypto trades securely and efficiently. By offering a private and tailored trading experience, OTC desks help mitigate the risks of slippage and market impact, ensuring that large transactions occur smoothly. This makes OTC desks an essential component of the crypto trading ecosystem, providing a reliable solution for those needing to buy and sell large amounts of crypto assets.

Why Crypto OTC Desks Matter More Than Ever

Before diving into MiCAR’s impact, it’s important to understand why crypto OTC desks are so vital:

  • Large volumes of crypto assets can destabilize prices on traditional exchanges. OTC desks mitigate market impact by executing trades discreetly between two parties, which helps minimize risks and affect the overall cost due to factors like slippage and market liquidity.

  • Institutional investors, high net worth individuals, and payment processors often need to buy and sell large amounts of crypto without causing price volatility.

  • OTC trading offers secure, private, and efficient settlements, providing access to a wider range of digital assets than many crypto exchanges.

  • Counter OTC trading desks serve as intermediaries for large cryptocurrency transactions between two parties without public visibility, facilitating high-volume trades that are less affected by market fluctuations compared to traditional exchanges.

Today, crypto OTC desks exist as critical infrastructure for high volume transactions, particularly in markets where minimum order size requirements and counterparty risks demand customized solutions. When trading large volumes, using experienced trading desks is crucial to avoid fragmented liquidity and opaque market depth on exchanges.

Benefits of OTC Trading

OTC trading offers numerous benefits that make it an attractive option for traders dealing with large volumes of crypto assets. One of the primary advantages is the deep liquidity provided by OTC desks, which ensures that traders can access competitive prices without significantly impacting the market. This is particularly important for institutional investors and high net worth individuals who require the ability to trade large amounts of crypto assets efficiently.

In addition to liquidity, OTC desks offer personalized service and flexibility, tailoring their offerings to meet the specific needs of each client. This level of customization is crucial for traders looking to execute large trades securely and with minimal market disruption. Furthermore, OTC trading provides a secure and efficient trading experience, with transactions conducted privately between two parties, reducing the risk of slippage and ensuring that trades are executed at the desired price.

MiCAR: Reshaping the OTC Crypto Market

The Markets in Crypto-Assets Regulation (MiCAR) aims to create a single regulatory framework for crypto assets across the EU, addressing issues like market manipulation, investor protection, and financial stability.

For crypto OTC desks, MiCAR changes the game:

  • Authorization is mandatory to offer crypto asset services to EU clients.

  • Transparency requirements will standardize how large orders and trades are reported.

  • KYC/AML protocols must meet rigorous EU compliance standards.

  • Capital requirements will ensure the financial resilience of service providers.

Becoming a MiCAR-regulated OTC desk is no longer optional for firms that want access to Europe’s growing crypto asset markets.

This content is not a solicitation directed at U.S. entities or individuals regarding securities.

Looking for liquidity, exploring on-ramp/off-ramp services, or seeking expert guidance?

Challenges on the Road to MiCAR Compliance

Achieving MiCAR authorization isn’t just about filling out paperwork. It requires a full transformation of how crypto OTC desks operate.

1. Licensing and Authorization

Every MiCAR-compliant OTC desk must:

  • Obtain authorization from a national competent authority (NCA).

  • Meet minimum own funds requirements.

  • Design and maintain robust security access protocols.

  • Implement anti-market abuse systems.

Getting licensed could take months and will involve extensive audits of internal controls. Additionally, institutions benefit from tailored services that cater to their need for handling significant transactions and providing deep liquidity, highlighting their importance in the crypto trading ecosystem.

2. Transparency and Reporting

OTC desks will need to provide:

  • Minimum trade amount disclosures.

  • Real-time transaction reporting to regulators.

  • Ongoing updates on trading volumes and counterparties.

This level of transparency is new for over the counter crypto trading, where discretion and privacy have historically been the norm. Various cryptocurrencies can be traded on OTC crypto exchanges, offering users the benefit of executing large transactions without public disclosure.

3. Operational Resilience

MiCAR mandates that OTC desks must demonstrate they can:

  • Handle operational shocks like high trading volumes or market crashes.

  • Secure client assets even during system outages.

  • Safeguard client funds separately from corporate assets.

Resilience will be tested not just by market conditions but also by regulators.

4. Anti-Money Laundering (AML) and Counterterrorism Financing (CTF)

Crypto OTC desks must comply with stringent AML/CTF requirements:

  • Conduct due diligence on all clients.

  • Monitor transactions for suspicious activity.

  • Report questionable activity promptly.

Maintaining this level of vigilance while ensuring high-volume, fast-paced trading will be challenging.

Opportunities for MiCAR-Regulated OTC Desks

Despite the hurdles, MiCAR compliance unlocks massive opportunities. Crypto OTC desks exist to facilitate high volume transactions for traders who require a more customized trading experience.

1. Institutional Trust

Institutional investors seek regulated partners. A MiCAR license signals that an OTC desk is a safe, transparent, and legitimate service provider — essential for onboarding banks, funds, and corporate clients.

OTC derivatives play a crucial role in enhancing investment strategies, offering flexibility for aligning investments with specific financial objectives.

2. Competitive Advantage

Early adopters of MiCAR standards will capture market share before competitors catch up. Crypto OTC desks that proactively meet regulatory standards will be trusted more by clients needing secure access to large amounts of crypto.

Our platform supports multiple fiat currencies, including the euro (EUR), to enhance users' trading flexibility and options.

3. Pan-European Market Access

With MiCAR’s passporting rules, an authorized crypto OTC desk can offer services across all EU member states without additional local licensing — dramatically expanding the addressable market.

The CoinsPaid OTC crypto exchange supports a diverse selection of currencies, including USD, enhancing the trading experience for customers.

4. New Revenue Streams

MiCAR authorization enables crypto OTC desks to diversify services:

  • Launch trading desks for asset-backed tokens.

  • Offer personalized services for portfolio management.

  • Provide secure custody and escrow services alongside trading.

With rising institutional interest in digital assets, these services are poised for growth. The platform's ability to facilitate trading in multiple currencies, including GBP, enhances the trading experience for users.

Practical Steps to Becoming a MiCAR-Regulated OTC Desk

1. Build a Compliance-First Culture

Compliance must be embedded across operations:

  • Train staff on new requirements.

  • Appoint a dedicated Compliance Officer.

  • Create a culture where preventing market abuse and ensuring transparency are top priorities.

A trading desk plays a crucial role in over-the-counter (OTC) trading, offering benefits such as managing larger volume transactions and mitigating exchange-related risks.

2. Upgrade Infrastructure

To support high volume transactions while maintaining compliance, desks must:

  • Implement scalable trade matching systems.

  • Integrate real-time AML screening.

  • Deploy secure storage for client funds.

  • Ensure robust reporting and audit trails.

Additionally, our OTC crypto exchange services offer competitive exchange rates and minimized market impact, enhancing the trading experience for substantial volumes of crypto.

3. Partner Strategically

Collaborations can ease the transition:

  • Partner with banks for fiat on/off ramps.

  • Work with regulated custodians for asset storage.

  • Use third-party compliance and AML technology providers.

Smart partnerships enable faster, more efficient MiCAR adaptation. Additionally, counter OTC desks play a crucial role in facilitating large cryptocurrency transactions between two parties without public visibility, ensuring these trades are less affected by market fluctuations compared to traditional exchanges.

4. Engage with Regulators Early

Proactively engaging with your NCA can:

  • Clarify licensing requirements.

  • Smooth the authorization process.

  • Build goodwill and reduce regulatory friction over time.

5. Building a Compliant Trading Platform

Building a compliant trading platform is essential for any OTC desk aiming to operate within the regulatory framework set by MiCAR. This involves adhering to a range of regulations designed to protect clients and ensure market integrity. A compliant trading platform must implement robust security measures to safeguard clients’ funds and personal data, ensuring that all transactions are conducted securely.

Transparency is another critical aspect of compliance. A compliant trading platform must offer transparent pricing and fees, ensuring fairness and building trust with clients. Additionally, OTC desks and trading platforms must comply with anti-money laundering (AML) and know-your-customer (KYC) regulations, conducting thorough due diligence on all clients and monitoring transactions for suspicious activity.

Ongoing monitoring and maintenance are crucial to ensure continued compliance with relevant regulations, including MiCAR. This involves regularly updating systems and processes to meet evolving regulatory requirements and providing deep liquidity and competitive prices to traders. By prioritizing compliance, OTC desks can build a secure and trustworthy trading environment that meets the needs of institutional investors and high net worth individuals.

Common Misconceptions About MiCAR and OTC Desks

"Only exchanges need to comply."

False.
MiCAR applies to all firms providing crypto asset services, including OTC desks handling large crypto trades.

"Compliance will kill OTC privacy."

Not entirely.
While transparency is mandatory, discreet execution and privacy around pricing remain core to OTC trading — so long as client identities and compliance needs are respected.

"It's better to delay until enforcement starts."

Risky strategy. Early movers will not only comply but also dominate the MiCAR era. Waiting risks lost business and heavy fines. This content is not a solicitation directed at U.S. entities or individuals regarding securities.

Conclusion

Becoming a MiCAR-regulated crypto OTC desk is not easy, but it’s the future-proof path for those serious about long-term success. As regulatory frameworks mature, only those firms that can offer secure, compliant, and high-volume trading services will survive.

At FinchTrade, we have embraced the road to MiCAR compliance. We believe that large transactions, deep liquidity, and secure OTC trading must now go hand-in-hand with full regulatory transparency.

Whether you’re an institutional investor, a payment processor, or a crypto business needing personalized service for large trades, partnering with a MiCAR-ready desk ensures you’re building your future in a compliant, resilient ecosystem. Crypto OTC desks exist to facilitate high volume transactions for traders who require a more customized trading experience.

For requesting more information about how we can help reach out to us. We're here to help and answer any questions you may have.

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