Buy-side CASP acquisition · Finland
Buy a CASP in Finland: MiCA-authorised crypto licence
Finland ran one of the shortest national MiCA transition windows in the EU and closed it on 30 June 2025, which means the Helsinki CASP pool is unusually narrow and unusually clean. Coinmotion took the first MiCA-CASP authorisation from FIN-FSA in July 2025; every Finnish entity offering crypto-asset services after that date carries a full Title V authorisation rather than a grandfathered registration. We broker change-of-control transactions on FIN-FSA-supervised CASPs to acquirers who want a small Nordic pool, an English-fluent supervisor, and EU passporting from a jurisdiction whose AML regime is already at the top end of EBA’s peer reviews.
Why Finland
A short pool, a closed transition window, and a supervisor that punches above its size
The Financial Supervisory Authority (FIN-FSA, Finanssivalvonta in Finnish) is the competent authority for crypto-asset service providers in Finland under Article 62 of Regulation (EU) 2023/1114 and the national implementing statute, the Crypto-Asset Markets Act (Act 402/2024). FIN-FSA shares a building with the Bank of Finland, takes correspondence in Finnish, Swedish, and working English, and runs a substantive review out of its Banking and Insurance Supervision department coordinated with its Anti-Money Laundering function. The supervisory dialogue is direct, the file expectations are written down, and the Article 83 change-of-control assessment is calibrated to the same prudential standard FIN-FSA applies to credit institutions and investment firms.
Finland made a deliberate choice to compress its MiCA transition. Operators previously registered under the Act on Virtual Currency Providers had to file a complete MiCA-CASP application by 30 October 2024 to keep operating into the window, and the window itself ended 30 June 2025. Several EU member states are still running grandfather periods into mid-2026; Finland is not. The acquirer reading is that any Finnish entity providing crypto-asset services in 2026 holds a fresh, fully reviewed Title V authorisation rather than a transitional permission with an expiry date attached.
The credibility signal sharpened with Coinmotion’s first authorisation in July 2025 (the Jyväskylä-headquartered exchange that had operated for over a decade under the prior Finnish virtual-currency regime). The takeaway is what the headline confirms more than the headline itself: FIN-FSA’s review apparatus works on real applicants, the Article 83 dossier expectations are visible in practice, and the resulting authorisation passports across the EEA without further notification beyond the Article 65 procedure. Finland is a credibility play with scarcity. The authorised pool is narrow because the supervisor’s bar is high and the country is small.
What a Finnish MiCA-CASP authorisation permits
Title V scope, Article 67 capital classes, and the obligations the buyer inherits
A Finnish CASP authorisation is granted under MiCA Title V and unlocks the full menu of crypto-asset services: custody and administration of crypto-assets on behalf of clients, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, execution of orders, placing of crypto-assets, reception and transmission of orders, advice, portfolio management, transfer services, and operation of a trading platform. Each service is named in the authorisation, and adding a service post-issue requires an Article 64 modification reviewed by FIN-FSA on a separate file.
Permanent minimum own funds sit at three classes under MiCA Article 67. Class 1 services (advice, reception and transmission of orders, transfers) are floored at EUR 50,000. Class 2 (execution, exchange of crypto-assets for funds or for other crypto-assets, placing) raises the floor to EUR 125,000. Class 3 (custody and administration, operation of a trading platform) takes it to EUR 150,000. The permanent minimum is the floor only; the binding figure is the higher of the floor and one quarter of the previous year’s fixed overheads. On a mature operating target the overheads test almost always sets the level, and Finnish CASPs trend mature because most live entities converted from established virtual-currency businesses with real revenue.
Article 75 requires segregation of clients’ crypto-assets from the CASP’s own holdings, with reconciliation discipline and clear contractual disclosures. Article 68 sets the prudential governance frame: at least two fit-and-proper executive directors with crypto-relevant experience, organisational structure proportionate to the service mix, internal control and compliance functions resourced to do their job, and a documented business continuity plan. DORA (Regulation 2022/2554) layers ICT risk management on top from January 2025, and the Travel Rule under Regulation 2023/1113 governs originator and beneficiary information on crypto-asset transfers. The acquirer inherits all of this at completion, including any open FIN-FSA correspondence.
What we broker here
The Finnish CASP files we work with
The Finnish CASP book is small and the inventory is shallow. That is exactly why a buy-side mandate beats a public listing search. Our Finland mandates fall into a few patterns: former virtual-currency-providers who completed the MiCA conversion before the 30 June 2025 sunset and are now exiting on the back of a strategic decision; Helsinki or Tampere-domiciled greenfield entities that obtained a fresh CASP authorisation explicitly with an exit in mind; and Finnish subsidiaries of Nordic crypto-banking or fintech groups whose parent is restructuring the licence stack and divesting one node.
Our diligence gates on every Finland file are banking continuity (the credit institution holding segregated client crypto-asset proceeds, typically a Finnish or wider Nordic bank, and the timeline to re-paper the relationship post-completion), the AML programme under the Finnish Anti-Money Laundering Act and MiCA Title V (transaction monitoring, sanctions screening, the MLRO’s seniority and replaceability), the substance pillar (Helsinki or Espoo-resident management, locally executed decision-making, and the support functions FIN-FSA expects under its real-presence test), and the technology stack (custody architecture, key-management arrangements, and the third-party providers inside the audit perimeter). We do not list the same target with multiple acquirers, and we will not present an entity we have not personally diligenced against FIN-FSA’s published expectations.
Acquisition path
Article 83 change-of-control, in practice
The acquisition mechanic for a Finnish CASP is governed by Article 83 of MiCA. Any proposed acquirer of a qualifying holding (10%, 20%, 30%, or 50% thresholds, or any holding that confers control) must notify FIN-FSA in writing before the transaction completes. The supervisor acknowledges the notification, opens the assessment window of up to 60 working days, and may extend it once by a further 30 working days when it requests further information. Assessment criteria mirror the prudential framework FIN-FSA applies across credit institutions and investment firms: reputation of the proposed acquirer, suitability of incoming directors, financial soundness, ability to comply with MiCA on an ongoing basis, and AML/CFT risk. Finland’s AML standards sit at the top end of the EBA’s peer reviews; the financial-soundness test is read accordingly.
What shortens the window is a complete dossier delivered with the initial notification, not after FIN-FSA’s first request for additional information. We build that dossier with our acquirers before signing: ultimate beneficial owner disclosure, sources-of-funds, group ownership chart, three-year prudential plan, governance arrangements at the target post-completion, and the status of any open supervisory items. See the acquisition process for the standing checklist.
Why Cadena
Where our buy-side CASP mandate beats the alternatives
- FIN-FSA-fluent dossiers. Our acquirers’ Article 83 packages are written to the supervisor’s published assessment framework before signing, not retrofitted after the regulator pushes back. That converts a procedural 60-working-day window into a working one.
- Single-side mandate, every file. We act for the acquirer only. The Finnish target’s adviser sits across the table from us on every CASP transaction, never on the same side. That removes the conflict-of-interest cloud that mixed-mandate brokers carry into a supervisor’s review.
- Closed-transition arithmetic. Finland’s transition window already closed on 30 June 2025, so the population is binary in a way that other EU member states’ populations are not. Either the target holds a live FIN-FSA authorisation or it does not provide crypto-asset services in Finland. There is no in-between to diligence around. That makes the inventory short but the targets clean.
FAQ
Frequently asked: Finnish CASP and MiCA acquisitions
Can I buy a CASP licence for sale in Finland rather than apply de novo?
Yes, when the underlying entity holds a current FIN-FSA authorisation under Article 63 of MiCA. The transaction is a change-of-control under Article 83: you notify FIN-FSA of the proposed qualifying holding, the supervisor runs a fit-and-proper assessment of the acquirer and incoming directors, and the deal completes on the supervisor’s non-objection. We broker only entities whose authorisation is live and whose current management have signalled willingness to exit on a clean change-of-control basis. The Finnish pool is short, so the diligence-to-deal ratio is high; we screen out targets who are open to a sale only at headline-grabbing valuations.
What is the difference between a CASP and a MiCA licence in Finland?
They are the same authorisation, named two ways. “MiCA licence” is the colloquial term acquirers use because the regulation creates the regime; “CASP authorisation” is what FIN-FSA actually issues, because the authorised entity is a Crypto-Asset Service Provider. The licence text references Title V of Regulation (EU) 2023/1114 and the Finnish implementing statute, the Crypto-Asset Markets Act 402/2024. Both terms point at the same FIN-FSA decision and the same passporting rights across the EEA.
Can a Finnish CASP licence passport across the EU?
Yes. Article 65 of MiCA gives any authorised CASP an EEA-wide passport to provide its scoped services in any other EU member state through a notification rather than a fresh authorisation. The acquirer inherits Finland’s passporting rights at completion. The passport covers exactly the Title V services named in the original FIN-FSA authorisation; expanding into adjacent services after closing requires an Article 64 modification first. Finland’s English-fluent supervisory dialogue makes the passporting notifications particularly clean to assemble.
How does Article 83 change-of-control approval work for a Finnish CASP?
You file a written qualifying-holding notification with FIN-FSA before the transaction closes. The supervisor has 60 working days from acknowledged-complete notification to assess, extendable by 30 working days where it requests further information. Assessment criteria are reputation, suitability of incoming directors, financial soundness, MiCA-compliance capability, and AML/CFT risk. The dossier mirrors what an acquirer would file for a qualifying-holding in a Finnish credit institution under the CRD framework; FIN-FSA calibrates the standard the same way and reads UBO transparency strictly.
How long does a fresh CASP authorisation take at FIN-FSA, and is buying faster?
FIN-FSA quotes an indicative 6 to 9 months for a complete fresh CASP application from filing to grant, longer where the file is incomplete or the applicant’s group structure raises substantive questions. A change-of-control on an already-authorised target runs to a 60-working-day statutory window plus the SPA timeline, which compresses the calendar materially when the target’s authorisation is in place at signing. The acquirer pays for the authorisation that already exists rather than for the wait.
Is buying a MiCA licence in Finland different from buying one in Lithuania or Estonia?
The MiCA framework is identical across member states; the supervisor and the candidate pool differ. Finland’s CASP-authorised population is small, the supervisor moves at a measured pace and reads files strictly, and the substance test is real (Helsinki-resident management, locally executed decisions). Lithuania’s market is wider but the Bank of Lithuania is more procedural; Estonia is mid-way through a multi-year cleanup of its prior virtual-currency-provider regime that affects the diligence on legacy entities. Compare the Lithuanian CASP and Estonian CASP pages for the side-by-side. The choice is rarely about the licence itself; it is about which regulator’s reputation the acquirer wants stamped on the entity.
Next step
Open a buy-side mandate on Finnish CASPs
If your acquisition thesis points at MiCA-CASP coverage with FIN-FSA quality and a Nordic risk profile, send us your acquisition criteria. We come back with the targets that match: pre-vetted on FIN-FSA standing, banking continuity, AML programme, post-conversion file status where relevant, and Article 83 readiness. If Finland turns out to be the wrong fit on diligence, the same engagement covers EU CASP comparables in adjacent member states.
