How Key2Law helped a crypto business enter the EU market via Bulgarian VASP

Entering the EU crypto market ahead of full MiCA authorisation requires a legally sound strategy that balances speed, regulatory certainty, and long-term compliance. In this case, Key2Law supported a crypto-asset services provider planning to offer fiat-to-crypto and crypto-to-fiat exchange services by designing a compliant market entry through the acquisition of an existing Bulgarian VASP. This approach ensured lawful operations during the MiCA transitional period, regulatory continuity under EU AML/CFT rules, and a solid foundation for future MiCA licensing.

Client

A crypto-asset services provider planning to operate within the EU market, offering fiat-to-crypto and crypto-to-fiat exchange services. The client sought a fast and legally compliant market entry solution while preparing for full MiCA authorisation.

Challenge

The client aimed to commence operations in the European Union as soon as possible. 

At the same time, the client required:

• Legal certainty and regulatory continuity;
• Compliance with EU AML/CFT requirements;
• A lawful basis to operate during the MiCA transitional period.

Navigating national VASP regimes alongside MiCA transitional provisions required careful regulatory analysis and structuring.

Solution

Key2Law advised the client on a strategic market entry approach by acquiring an already registered Bulgarian Virtual Asset Service Provider (VASP).

Leveraging Bulgaria’s national implementation of the MiCA transitional regime, we structured the transaction to ensure that the acquired entity could continue providing crypto-asset services until 1 July 2026, in accordance with applicable EU and Bulgarian law.

Our services included:

• Comprehensive due diligence of the target Bulgarian VASP;
• Verification of AML/CFT compliance, internal policies, and regulatory standing;
• Structuring and execution of the VASP acquisition;
• Alignment of the acquired entity’s governance and compliance framework with MiCA requirements.

Process

1. Regulatory strategy assessment: analysis of MiCA transitional provisions and Bulgarian national legislation to confirm eligibility for continued operation.
2. Target selection & Due diligence: comprehensive regulatory and compliance due diligence of the existing VASP.
3. Transaction structuring: structuring the acquisition to preserve regulatory continuity and operational validity.
4. Post-acquisition alignment: updating internal policies, AML procedures, and governance to ensure MiCA readiness.

Result

1. The client obtained a fully operational EU-based VASP;
2. Lawful continuation of crypto-asset services until 1 July 2026 under the Bulgarian transitional regime;
3. Immediate market entry without regulatory disruption;
4. A compliant foundation for a future MiCA licence application.

This approach allowed the client to operate legally while preparing for long-term MiCA compliance, significantly reducing time-to-market and regulatory risk.

Planning to enter the EU crypto market under MiCA? Contact Key2Law to explore strategic VASP acquisition and MiCA-ready licensing solutions.