Buy-side CASP acquisition · Latvia
Buy a CASP in Latvia: MiCA-authorised crypto licence
Latvijas Banka issued the country’s first two CASP authorisations in December 2025, with five more applications submitted and twelve additional applicants engaged in pre-licensing consultations. The Latvian pool is the smallest in the Baltic region, the supervisor’s review posture is the most collaborative in the EU, and the acquirer who moves now sits ahead of the dispersion that will follow as the cohort matures. We broker change-of-control transactions on Latvijas Banka-authorised CASPs to acquirers who want a clean MiCA authorisation, EU passporting, and a regulator that publishes its expectations rather than negotiating them after filing.
Why Latvia
A regulator-led market, opened deliberately, with the smallest authorised pool in the Baltics
The competent authority for crypto-asset service providers in Latvia is Latvijas Banka, the country’s central bank and integrated financial regulator since the 2023 merger that absorbed the former Financial and Capital Market Commission. Latvijas Banka exercises MiCA-CASP authorisation under Articles 62 to 63 of Regulation (EU) 2023/1114, with qualifying-holding disclosures governed by its own Regulation No. 241. The supervisor took an unusually collaborative posture into the regime: from August 2024 it offered free pre-licensing consultations to prospective applicants, with no cap on the number of meetings, and continues that approach into 2026.
The result is a pool that is small by design rather than by accident. Two CASP authorisations were issued by December 2025, with five more applications then on file and twelve applicants in active pre-licensing dialogue. By comparison, Lithuania’s authorised population sits in the dozens and Estonia’s legacy virtual-currency cleanup still casts a shadow over its CASP pipeline. Latvia is the cleanest sheet of the three Baltic markets, and Latvijas Banka’s review apparatus reads files against published expectations instead of negotiating them after filing.
That posture matters for an acquirer. A Latvijas Banka-authorised CASP is the product of a supervisory dialogue that started with the regulator before the application was submitted, not after. The Article 83 change-of-control file inherits that posture. The substance test, the AML programme, and the technology-stack disclosures are all built to a known framework rather than a moving target. Smaller pool, harder targets to find, but the targets that do exist arrive with less embedded supervisory risk than in jurisdictions where the regulator improvised its way through 2024.
What a Latvian MiCA-CASP authorisation permits
Title V scope, Article 67 capital classes, and what the buyer inherits
The authorisation grants the full menu of MiCA Title V crypto-asset services: custody and administration of crypto-assets on behalf of clients, operation of a trading platform, 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 on crypto-assets, portfolio management of crypto-assets, and transfer services. Each service is named on the authorisation. Adding a service after authorisation requires an Article 64 modification reviewed by Latvijas Banka on a separate file, so the scope at completion is the scope you operate.
Permanent minimum own funds follow MiCA Article 67’s three-class structure. 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, trading-platform operation) takes the floor to EUR 150,000. The binding capital figure is the higher of that floor and one quarter of the previous year’s fixed overheads. On a real operating target the overheads test usually sets the actual capital level, and Latvijas Banka cross-checks the calculation against the audited financials in the dossier.
Article 75 requires segregation of clients’ crypto-assets and funds 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, an 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 (Regulation 2023/1113) governs originator and beneficiary information on crypto-asset transfers. The acquirer takes all of this at completion, including any open Latvijas Banka correspondence and any pending supervisory items.
What we broker here
The Latvian CASP files we work with
The Latvian CASP book is the shallowest in the Baltic region, and our position on it reflects that. Listing-broker approaches do not work in this market. The two entities that hold authorisations were not on a public roster before they were licensed and they will not be on one after; the eight to fifteen entities that will be authorised by end-2026 will follow the same pattern. The only reliable route to a Latvian CASP acquisition is a buy-side mandate that opens private dialogue with named targets, which is precisely the engagement we run.
Our diligence gates on every Latvia file are banking continuity (the credit institution holding segregated client crypto-asset proceeds, often a Baltic or wider Nordic bank, and the timeline to re-paper the relationship after completion), the AML programme under Latvian implementing law and MiCA Title V (transaction monitoring calibrated to Latvia’s national risk assessment, sanctions screening including the EU sectoral regime, and the MLRO’s seniority and replaceability), the substance pillar (Riga or Latvia-resident management with locally executed decision-making and the support functions Latvijas Banka expects under its real-presence reading), and the technology stack (custody architecture, key-management arrangements, and the third-party providers inside the audit perimeter). We do not present an entity we have not personally diligenced against Latvijas Banka’s published file expectations.
Acquisition path
Article 83 change-of-control with Latvijas Banka, in practice
The acquisition mechanic is governed by Article 83 of MiCA, layered with Latvijas Banka Regulation No. 241 on qualifying-holding disclosures. Any proposed acquirer of a qualifying holding (10%, 20%, 30%, or 50% thresholds, or any holding that confers control) must notify Latvijas Banka in writing before the transaction closes. The supervisor acknowledges the notification, opens the assessment window of up to 60 working days, and may extend by a further 30 working days where it requests further information. Assessment criteria are the standard MiCA set: reputation of the proposed acquirer, suitability of incoming directors, financial soundness, ability to comply with MiCA on an ongoing basis, and AML/CFT risk, calibrated against Latvia’s national risk assessment and the regulator’s view on the proposed group structure.
What shortens the window is a complete dossier delivered with the initial notification, which is also where Latvijas Banka’s collaborative posture pays off: the regulator will engage in pre-notification dialogue on the contemplated transaction structure if asked, and that dialogue routinely surfaces the dossier gaps that would otherwise generate a 30-working-day extension request. We build the 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 every open supervisory item. See the acquisition process for the standing checklist.
Why Cadena
Where our buy-side CASP mandate beats the alternatives
- Single-side mandate, every file. We act for the acquirer only. The Latvian 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 of an Article 83 file.
- Latvijas Banka-fluent dossiers. Our acquirers’ Article 83 packages are written to the supervisor’s published assessment framework before signing, with the pre-notification consultation built in to the timeline rather than tacked on at the end. The dossier reaches Latvijas Banka in a state the regulator recognises immediately, which is what converts a 60-working-day procedural window into a working one.
- First-mover access in a private market. The Latvian CASP population is too shallow for listing services to function. We open dialogue with named targets directly, which is the only mechanism that surfaces Latvian inventory at all. Acquirers who wait for a public marketplace will still be waiting in 2027.
FAQ
Frequently asked: Latvian CASP and MiCA acquisitions
Can I buy a CASP licence for sale in Latvia rather than apply de novo?
Yes, when the underlying entity holds a current Latvijas Banka authorisation under Article 63 of MiCA. The transaction is a change-of-control under Article 83: you notify Latvijas Banka 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. Latvia’s authorised pool is small (two by December 2025, with single-digit growth expected through 2026), so listings do not exist in any usable form. A buy-side mandate that approaches named targets directly is the only reliable acquisition route.
What is the difference between a CASP and a MiCA licence in Latvia?
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 Latvijas Banka actually issues, because the authorised entity is a Crypto-Asset Service Provider. The licence text references Title V of Regulation (EU) 2023/1114 and Latvijas Banka’s national licensing framework. Both terms point at the same Latvijas Banka decision and the same passporting rights across the EEA.
Can I buy a MiCA licence in Latvia and operate 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 Latvia’s passporting rights at completion. The passport covers exactly the Title V services named in the original Latvijas Banka authorisation; expanding into adjacent services after closing requires an Article 64 modification first. Latvia’s English-fluent supervisory dialogue and the regulator’s collaborative posture make passporting notifications particularly clean to assemble from a Riga base.
How does Article 83 change-of-control approval work for a Latvian CASP?
You file a written qualifying-holding notification with Latvijas Banka before the transaction closes, structured per Latvijas Banka Regulation No. 241. 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 against Latvia’s national risk assessment. Latvijas Banka offers pre-notification consultation to the proposed acquirer, which is the lever that compresses the 60-working-day window in practice.
How long does a fresh CASP authorisation take at Latvijas Banka, and is buying faster?
Latvijas Banka does not publish a fixed indicative timeline, but the trajectory of the first cohort suggests roughly 9 to 12 months from complete application to grant for an applicant who has used the pre-licensing consultation process; 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 the 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 Latvia different from buying one in Lithuania or Estonia?
The MiCA framework is identical across EU member states; the supervisor and the candidate pool differ. Latvia’s CASP-authorised population is the smallest in the Baltics and the supervisor’s posture is the most collaborative — pre-licensing consultations are unlimited and free, and the file expectations are published. Lithuania has a wider market but the Bank of Lithuania is more procedural and acquisitive demand has compressed the inventory. Estonia is mid-way through a multi-year cleanup of its prior virtual-currency-provider regime that complicates diligence on legacy entities. Compare the Lithuanian CASP and Estonian CASP pages for the side-by-side. The choice rarely turns on the licence itself; it turns on which regulator’s reputation the acquirer wants stamped on the entity and which inventory matches the deal thesis.
Next step
Open a buy-side mandate on Latvian CASPs
If your acquisition thesis points at MiCA-CASP coverage with a Baltic risk profile and a regulator that publishes what it expects, send us your acquisition criteria. We come back with the targets that match: pre-vetted on Latvijas Banka standing, banking continuity, AML programme calibrated to Latvia’s national risk assessment, post-conversion file status where relevant, and Article 83 readiness. If Latvia turns out to be the wrong fit on diligence, the same engagement covers EU CASP comparables in adjacent member states.
