Regulatory
ORWL Avocats advises crypto-asset service providers, payment and e-money institutions, token and stablecoin issuers and tokenisation projects, from France and abroad, from the qualification of their business to ongoing compliance.
Specialists in banking and financial regulation, our lawyers have advised fintechs, exchanges, regulated institutions and foreign groups since 2018 and have handled several dozen authorisations. They combine the rigour of that discipline with close knowledge of crypto-asset services, stablecoins and tokenisation: business models, flows and technical constraints. We work in English and French before the AMF (Autorité des marchés financiers, the French financial markets regulator), the ACPR (Autorité de contrôle prudentiel et de résolution, the French Prudential Supervision and Resolution Authority), the Banque de France and the ANJ (Autorité nationale des jeux, the French gaming regulator).
MiCA has applied since 30 December 2024, and the transitional period for French-registered digital asset service providers (PSANs) ended on 1 July 2026: a provider without an authorisation or a passport must stop serving French clients, while a French authorisation can open the whole European Union. We advise on every rule at stake: MiCA, the Payment Services Directive (PSD2) and the Electronic Money Directive, the Digital Operational Resilience Act (DORA), anti-money laundering and counter-terrorist financing (AML/CFT) rules and the travel rule, MiFID II for tokenised financial instruments, and the ongoing revision of the payment services framework (PSD3 and the Payment Services Regulation, PSR).
How we can assist
Launching a project
Qualify the business and the tokens, choose the right status, prepare the offer.
Getting authorised
Build the application and handle the dialogue with the regulator through to the decision.
Staying compliant
Meet the commitments made in the application and adapt the organisation as the business changes.
Dealing with the regulator
Prepare for an inspection, respond to the AMF or the ACPR, organise an orderly exit.
Expertises
We advise crypto-asset and payment businesses throughout their regulatory life cycle, according to their status.
Crypto-asset service providers (CASPs)
AMF authorisation, ongoing MiCA compliance, AML/CFT and the travel rule, operational resilience, a new shareholder or a change of management, cessation of business: we advise CASPs at every stage of their regulatory life.
Payment and e-money institutions
Full authorisation, simplified authorisation (agrément simplifié), agent or e-money distributor status, dual status with a CASP authorisation, the Banque de France review of the security of payment means, and changes in capital subject to ACPR approval.
Issuers, stablecoins and tokenisation
Token qualification, crypto-asset white papers and admission to trading, stablecoin issuance, tokenisation of financial instruments and real-world assets, and legal opinions on token qualification for platforms that admit a token.
Foreign providers
MiCA passport, authorised French subsidiary, reverse solicitation, French marketing rules, removal from the AMF blacklist: we advise EU and third-country providers that serve the French market.
Crypto and Web3 start-ups
Games with monetisable digital objects (JONUM, a French regime), NFTs and marketplaces, DeFi protocols and staking, promotion by influencers and affiliates: we qualify the project and secure its launch.
Crypto-assets and MiFID II
Banks, investment firms and asset managers that provide crypto-asset services, CASPs that offer investment services or distribute tokenised fund units: we choose the route, handle the notification or the authorisation and reconcile MiCA and MiFID II.
AI agents, payments and crypto-assets
AI agents that initiate payments, place orders on crypto-assets or run a wallet: we qualify each function of the agent under PSD2 and MiCA and structure the product, both for the fintechs that build these agents and for the payment institutions and CASPs that open their services to them.
The firm also advises these businesses on the tax side of their activity, including the reporting obligations of CASPs under DAC8, through its tax practice.
Which activity, which status, which regulator?
| Activity | Status | Authority | How we help |
|---|---|---|---|
| Crypto-asset services | Crypto-asset service provider (CASP) authorisation | AMF, after an opinion from the ACPR | From the qualification of the services to authorisation, then day-to-day compliance. |
| Payment and e-money | Payment or e-money institution authorisation, simplified authorisation, agent or distributor | ACPR; Banque de France for the security of payment means | Choice of status, authorisation, long-term compliance. |
| Token and stablecoin issuance | Notification of a white paper; for an e-money token, credit institution or e-money institution status | AMF for most tokens; ACPR for stablecoins | Token qualification and a secure issuance. |
| Foreign provider | MiCA passport, authorised French subsidiary or reverse solicitation | Home-country authority; AMF | Access to the French market and local compliance. |
| Web3 games, NFTs and DeFi | Depending on the qualification: no status, a JONUM declaration or one of the statuses above | ANJ for JONUM; AMF or ACPR depending on the activity | Project qualification and a secure launch. |
| Crypto-assets and financial instruments | Article 60 notification for an institution already authorised; investment firm authorisation or a partnership for a CASP | ACPR or AMF depending on the institution; home-country authority for an institution authorised elsewhere in the EU | Choice of route, notification or authorisation, distribution agreements. |
| AI agents and payments | Depending on what the agent does: no status, payment institution or CASP authorisation, or reliance on an authorised partner | ACPR for payment services; AMF for crypto-asset services | Qualification of each function of the agent and structuring of the product. |
Why ORWL Avocats?
We advise regulated institutions and applicants for authorisation on the matters that determine their status: qualification, authorisation, governance, own funds, internal control and relations with the supervisory authorities. The authorisations we handle before the AMF and the ACPR concern fintechs, exchanges, regulated institutions and foreign groups. The firm is ranked by Chambers and Partners in FinTech and by Leaders League in blockchain.
As a boutique firm, we have particular command of crypto-asset services, stablecoins and tokenisation: business models, technical flows and the distinctions that determine status, such as the one between exchange and the execution of orders. A partner leads every matter. Where needed, the firm coordinates its clients’ accountants, cybersecurity providers, insurers and banks.
The firm contributes to legal scholarship and industry policy work. William O’Rorke, partner, is the author of Droit des crypto-actifs (LexisNexis, in French) and of the “PSCA” chapter of the LexisNexis encyclopaedia. He teaches the regulation of crypto-assets at the Paris Bar School (EFB) (in French) and in several master’s programmes. ORWL Avocats is involved in ADAN, the French association for the development of digital assets, where William O’Rorke sits on the board.
A lawyer’s advice gives your business a legal qualification, engages the lawyer’s professional liability and is protected by legal professional privilege.
Team
Our team brings together lawyers in banking and financial regulation who understand how crypto-assets and payments work technically. We work with a network of partners to provide complete support: cybersecurity firms, accountants, statutory auditors, insurance brokers, banks and law firms in other jurisdictions.
Contact us
Tell us about your project or situation: a lawyer from the Regulatory team will get back to you to assess what is at stake.
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