ESMA Q&A – Article 78(5) MiCA
ESMA confirms that this obligation applies whenever a CASP’s execution policy allows orders to be executed outside a MiCA-authorised trading platform, including OTC venues, third-country platforms or decentralised exchanges.
About the author
Cécile Henry
Regulatory and compliance expert at Seqlense. Cécile authors every Seqlense Note — bringing hands-on experience and a pragmatic approach to regulatory analysis, with a focus on real operational impact rather than abstract theory. Her work covers French, Luxembourg and Belgian regulators, EU frameworks (MiCA, DORA, AML), and the operational reality of compliance in financial services and crypto.
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