A workbook for junior lawyers · EU law
Crypto-Asset Regulation
Halcyon Digital Assets Limited runs a crypto-asset app from Dublin and keeps €94,000,000 of its 48,000 users' crypto-assets. On 12 November 2025 the Central Bank of Ireland authorised it under MiCA, the EU's rulebook for crypto-assets, for five services. You join its legal team two months later, as the licence meets its first year. A Travel Rule failure, a market-abuse alert, a six-hour outage and a sixth service each land on your desk. Chapter by chapter you learn to read an authorisation, run an incident on DORA's clocks and draft the next application, against the full training compliance binder.
Chapter 1 is free to read now — what a crypto-asset is, what an exchange holds of yours, and why the state cares. The edition unlocks the other nine chapters, the full compliance binder and the 30-question exam.
How this workbook works
Plain words first, articles second
Every rule is stated in plain English before its article number appears, in brackets. A crypto-asset service provider is "the company that holds or trades crypto-assets for other people" before it is Article 3(1)(15). No sentence needs a regulator to read it.
Two sides to every rule
Each rule is introduced as a problem somebody had before there was a rule, and the objection of the people it costs is stated fairly. This is a regime that costs real money to obey. By the end you know why anyone obeys it, and why anyone resents it.
Test yourself
Every chapter ends with an 8-question test (pass mark 6). Finish with a 30-question final exam (pass mark 24). Your progress is saved to your Solon Press profile.
The case: Halcyon's year under a licence
Dublin, 12 November 2025. The Central Bank of Ireland authorises Halcyon Digital Assets Limited as a crypto-asset service provider, a "CASP": a company that holds or trades crypto-assets for other people. The authorisation lists five services: custody, exchange for euro, exchange of one crypto-asset for another, execution of client orders and transfers. It came eight months after the application went in, and, at the time of writing (2026), seven weeks before Ireland's transitional period ran out. Halcyon has been registered under the anti-money-laundering rules since 17 March 2022. Its app has 48,000 registered users, traded €310,000,000 in 2024, and holds €94,000,000 of clients' crypto-assets in custody. You join on 12 January 2026 as the third member of Legal & Compliance, a junior lawyer. You report to the Head of Legal and work daily with the Head of Compliance, who is also the Money Laundering Reporting Officer.
This workbook follows what the licence demands once the year turns difficult. In January 2026 one notification opens six more countries to Halcyon, with no new authorisation and no local office. In February a vendor's update sends 214 transfers, worth €387,000, without the sender's details. The Travel Rule is the law that makes those details go with every transfer. In April surveillance flags 1,180 trades in one token that were three accounts trading among themselves, and a report goes to the Central Bank. In May the custody provider's signing service fails for six hours and forty minutes, and 9,400 clients cannot withdraw. DORA, the EU's rules on technology resilience, puts the reporting on a clock. In June marketing is told that United Kingdom residents may not be onboarded, because MiCA stops at the EU's border. And on 1 September 2026 the board resolves to add a sixth service, a trading platform, which means a second application. You draft the gap analysis.
The full Compliance Binder is on this site: ten policies and four appendices, including the services register, the authorisation checklist and the incident timeline card. Every chapter links straight into its paragraphs.
The modules
Module 2
The Licence
- 03The Application — The file, the clocks, the own-funds arithmetic — and why completeness is the clock✓
- 04Governance and Conduct — Honest, fair and professional — the three lines, complaints, conflicts and the wind-down plan✓
- 05Custody, Client Money and the Stablecoin Question — Segregation, the credit institution, liability for loss — and why HalcyonEUR died✓
- 06The Passport, the Map of Regulators, and the Country That Left — Six member states in fifteen days; where firms go for a licence and why; the United Kingdom, where none of it applies✓
Module 3
Living With It
- 07AML and the Travel Rule — Due diligence, monitoring, the MLRO — and 214 transfers that left without their papers✓
- 08Market Abuse — Inside information, manipulation, surveillance — and the 1,180 trades that were three accounts✓
- 09DORA: When the Systems Fail — The framework, the clocks, the register — and six hours forty minutes without withdrawals✓
Reference shelf
The Compliance Binder
The complete training document: ten policies and four appendices. The perimeter and services register, governance, own funds, safeguarding, conflicts, complaints, the Travel Rule, market abuse, DORA and listing. Then the application checklist, the incident timeline card and the client-terms extracts.
Glossary
Every term of art used in this workbook, in plain English, each linked to the paragraph of the binder behind it.
Final Exam
Thirty questions across all ten chapters. Pass mark 24. Open book, like real practice.
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