Subject Matter
Transient exposure of EU client crypto-assets in a non-EU hot wallet during deposits, withdrawals and settlement
Question
In the context of in/out transfers (deposits/withdrawals) from an EU authorised CASP, can assets from EU clients temporarily be held in a (hot) wallet at an entity not authorised as a CASP under MiCA? Under what conditions, if any, would the temporary presence of EU client crypto-assets in that wallet be considered a purely technical/transient transfer step rather than custody, administration or transfer services being provided by the non-authorised entity?
Level 1 Regulation
MiCA