Regulatory - ORWL

For nearly a decade, ORWL_’s Regulatory team has been supporting crypto-asset players and financial institutions in ensuring compliance with the regulatory frameworks governing their activities.

Led by William O’Rorke, our team advises both Fintech and regulated institutions, helping them structure projects involving crypto-asset services, tokenisation, decentralised finance, and payment solutions.

Recognised by Leaders League and Chambers & Partners, our team has in-depth expertise across the full spectrum of applicable regulations — including MiCA (Markets in Crypto-Assets Regulation), MiFID II (Markets in Financial Instruments Directive II), PSD2/PSD3 (Payment Services Directive 2 and 3), EMD (Electronic Money Directive), and DORA (Digital Operational Resilience Act) — providing strategic guidance at every stage, from initial scoping to market launch.

Our expertise is built on long-standing engagement within both the crypto-asset industry and the development of legal doctrine:

William O’Rorke serves as a board member and secretary of ADAN, the leading European association for crypto-asset professionals, where he actively contributes to industry discussions and policy positions.
He is also the author of key academic and practical references, including the Manuel du droit des crypto-actifs (LexisNexis) and the “PSCA” entry in the Lexis Encyclopaedia, and lectures in banking and financial law at the Paris Bar School and in several of France’s leading specialised master’s programmes.

Services

Licensing and Authorisations: We assist clients in obtaining status as CASP (Crypto-Asset Service Provider), payment institution (PI), or electronic money institution (EMI), and are already preparing future CASP applications under the Markets in Crypto-Assets Regulation (MiCA).

Public Token Offerings: We draft and notify white papers (ICO, EMT, ART), ensuring full compliance with marketing, governance, and disclosure requirements.

Compliance and Cyber-Security: We carry out comprehensive regulatory audits — including Travel Rule, DORA (Digital Operational Resilience Act), and MiFID II (Markets in Financial Instruments Directive II) — and assist compliance teams in implementing operational remediation measures.

Legal Structuring: We ensure the regulatory soundness of your services through detailed legal opinions, precise qualification of crypto-assets, and a comprehensive risk mapping, delivering robust solutions designed to reassure users, investors, and regulators alike.

Expertises

Avocats spécialistes des émetteurs de stablecoins

Stablecoin Issuers

Achievements

Our generalist and industry-focused approach is reflected in a selection of notable achievements supporting both fintech and crypto projects.

CASP Authorisation

ORWL’s regulatory team supported a new market entrant seeking to offer crypto-assets’ services in France. Our work covered every stage of the application process, including the design of AML/CFT (Anti-Money Laundering and Counter-Terrorist Financing) procedures and the establishment of the organisational framework. We also assisted the fintech throughout its interactions with the Autorité des marchés financiers (AMF) and the Autorité de contrôle prudentiel et de résolution (ACPR), up to the successful granting of its licence.

MiCA White Paper for Trading Admission

ORWL advised on a project involving the secondary admission of a utility token on a trading platform. The regulatory team drafted and provided the legal qualification of the white paper, while supporting the issuer in its discussions with the AMF. This engagement ensured the project’s regulatory compliance and facilitated the token’s effective admission to trading.

CASP and PI Authorisation for a Fintech

ORWL’s regulatory team assisted a foreign fintech in obtaining dual authorisations as a Crypto-Asset Service Provider (CASP) and Payment Institution (PI), enabling it to offer an integrated service combining fiat and crypto. The assignment required close coordination with the AMF and ACPR, as well as a nuanced alignment between the requirements of MiCA (Markets in Crypto-Assets Regulation) and PSD2 (Payment Services Directive 2), particularly regarding orwn funds requirements, governance, and internal control mechanisms.

Regulatory structuring of a staking project

ORWL advised a client providing staking and lending services to both B2C and B2B customers. The regulatory team conducted an in-depth analysis of the potential risks of requalification (investment services, collective investment products) and proposed a compliant structuring model. We also carried out forward-looking monitoring on the evolution of European regulation — notably MiCA 2 and consultations from ESMA (European Securities and Markets Authority) and AMF — and supported the client in its exchanges with regulators.

Withdrawal from the AMF Blacklist of a major crypto player

ORWL’s regulatory team assisted a leading international crypto company in achieving regulatory compliance for its operations in France. We supported the firm in its interactions with the AMF and other national regulators to design and implement an orderly market exit plan, ultimately leading to its removal from the AMF blacklist.

Team

Our team is composed of experienced lawyers with a strong technical understanding of the crypto-asset industry. We also work closely with a trusted network of partners to provide our clients with seamless and comprehensive support — including cybersecurity firms, legal recruitment specialists, chartered accountants, statutory auditors, banking institutions, and foreign law firms.

William O’Rorke

Imane Dahmani