Exchanges / CASP
MiCA + AML without slowing down your business
"We turn requirements into real processes: onboarding, scoring, evidence and ongoing review. Practical compliance, not 'paperwork'."
Crypto Lawyers in Spain: Crypto-Assets & Blockchain
We are crypto lawyers in Spain providing expert legal advice on crypto-assets and blockchain: MiCA compliance, AML/CFT, the Travel Rule, on-chain traceability and defense against information requests, so you can operate with legal certainty.
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Services
Our crypto and blockchain legal services in Spain
Six pillars for working with crypto-assets with legal certainty, compliance and solid evidence.
Regulation
Token classification and legal opinions
We analyze each token individually (utility, security, NFT, stablecoin) and issue reports that support your decisions and your dealings with regulators and partners.
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UtilitySecurityNFTStablecoin
AML/CTF
Crypto compliance program
Policies, controls and designated officers: on-chain/off-chain KYC/EDD, sanctions, monitoring and evidence in line with AML/CFT rules.
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KYC/EDDOn-chainSanctionsEvidence
Traceability
Crypto traceability report
Verifiable source of funds: on-chain analysis, supporting documentation and a consistent narrative for audits, banks or investors.
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On-chainSource of funds
Travel Rule
Travel Rule implementation and controls
Data-flow design, risk-based criteria and evidence so you can deal with counterparties while reducing blocked transfers and operational friction.
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DataCounterparties
MiCA
CASP license and MiCA readiness
A documentation and operational roadmap: governance, policies, contracts, controls and preparation for registration/licensing and the EU passport.
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CASPEU passport
Defense
Information requests and inspections
Robust responses to the Spanish Tax Agency, banks and supervisors: risk analysis, documentation, strategy and consistency with how you actually operate.
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Tax AgencySupervisors
Sectors
Crypto compliance for every business model
Exchanges, custodians, DeFi platforms, token issuers or investors: each profile needs different controls and evidence.
On-chain & Off-chain
Traceability and source of funds
"We build verifiable dossiers: on-chain analysis, off-chain documentation and a consistent narrative for banks, investors or audits."
Travel Rule
Data, risk and evidence
"We design flows and criteria to share information in a controlled way, minimizing friction and maximizing traceability."
Web3
Governance and smart contracts
"We review operational risks, roles, controls and documentation. Less exposure, greater ability to respond."
Consequences
Why act now on crypto and blockchain compliance?
Crypto regulation is getting tougher: MiCA, the AMLR and the Travel Rule are already in force. Non-compliance blocks your operations, your access to banking and your reputation.
Significant penalties for non-compliance: heavy fines and the risk of an operational shutdown for VASPs/CASPs without adequate controls.
Tougher KYC/EDD expectations, plus on-chain analysis, source-of-funds checks and the Travel Rule to deal with counterparties.
Growing requirements for digital documentation and record-keeping of evidence (customers and beneficial owners).
MiCA / CNMV
Cessation of activity
Providing crypto services without CASP authorization: suspension of activity, fines and public disclosure of the breach.
De-banking
Loss of banking access
Banks, investors and partners cut ties if there are no verifiable AML controls, traceability and governance.
AMLR / Law 10/2010
up to €10,000,000
Penalties for very serious AML/CFT infringements applicable to crypto-asset service providers.
Need legal certainty in crypto-assets & blockchain?
We help you with regulation, AML compliance, the Travel Rule, MiCA, traceability and defense against information requests, so you operate with evidence and sound judgment.
Frequently asked questions
Crypto lawyers in Spain: common questions on crypto-assets and blockchain
What are crypto and blockchain legal services?
Legal and technical advice covering the regulatory, contractual and compliance aspects of crypto-assets and blockchain technology.
It includes token classification, the legal structuring of Web3 projects, AML/CFT policies, contract review and support before supervisors. The goal: to operate with sound judgment, evidence and legal certainty.
Which companies or projects need this advice?
Exchanges, custodians, wallet providers, token issuers, DeFi/CeFi platforms, crypto payment businesses, tokenized asset managers, NFT marketplaces and family offices/investors with crypto exposure.
If you intermediate digital assets or handle fiat↔crypto flows, compliance is no longer optional.
What do crypto and blockchain legal services include?
Regulatory and risk assessment, design of on-chain and off-chain KYC/EDD programs, the Travel Rule, counterparty due diligence, terms and conditions, smart contract review, licensing/registration and support in investigations and sanctions proceedings.
Always with a practical approach: processes, designated owners and evidence.
What is an external crypto compliance audit?
An independent (legal and technical) review that assesses how effective your compliance program is: KYC/EDD, monitoring, on-chain traceability, governance and internal policies.
It helps you detect gaps and serves as documentary evidence for audits or supervisors.
Why is specialized training key in blockchain?
Risk in crypto does not behave the way it does in traditional finance: on-chain patterns, mixers/bridges, complex structures and smart contract vulnerabilities.
Training + evidence = fewer operational errors and a stronger defense when you are reviewed.
What are the risks if I don't comply?
Penalties, blocked operations, disqualifications, reputational damage, loss of banking access and exposure to incidents due to missing AML controls and governance.
Prevention is cheaper than reacting late, especially as supervision intensifies.
What is MiCA and how does it affect my crypto project?
The MiCA Regulation (Markets in Crypto-Assets) sets a single EU regulatory framework for crypto-asset service providers (CASPs). It requires authorization and compliance with governance, capital, custody and transparency requirements.
If you operate as an exchange, custodian or crypto service platform, you need to comply with MiCA to keep operating and to access the EU passport.
What is the Travel Rule and why does it matter?
The Travel Rule requires crypto-asset service providers to share originator and beneficiary information on transfers. It is key to complying with AML rules and dealing with counterparties.
Without the Travel Rule in place, transfers can be blocked and your relationships with banks and other CASPs become harder.
Operational guide
A practical guide to crypto compliance
Crypto compliance is not just "having a manual": it is a set of workable controls adapted to on-chain and off-chain activity, backed by verifiable evidence. The key is a risk-based approach applied to digital assets.
What crypto compliance is for
Reducing the risk of money laundering, illicit finance and fraud in crypto-asset transactions through tailored controls, on-chain traceability and evidence you can defend before supervisors.
Minimum required controls
KYC/EDD, on-chain analysis, the Travel Rule, governance, capital and custody requirements, internal policies and an escalation channel. All documented and auditable.
What makes the difference
A crypto compliance program is proven by how it is executed: alert logs, on-chain analysis, justified decisions, minutes and periodic reviews are the first things examined.
Crypto compliance checklist in 10 steps
- Regulatory assessment: your business model (exchange, custody, wallet, DeFi, payments) and the rules that apply to it.
- Token classification: utility, security, NFT, stablecoin and the related obligations.
- AML/CFT program: KYC/EDD adapted to on-chain and off-chain activity, with roles and procedures.
- Travel Rule: data flows, risk-based criteria and evidence for dealing with counterparties.
- Traceability and source of funds: verifiable dossiers with on-chain analysis and supporting documentation.
- MiCA/CASP readiness: governance, documentation, capital and controls for registration/licensing.
- Screening: sanctions, PEPs, blacklists and adverse media alerts.
- On-chain monitoring: rules, thresholds, mixers/bridges, suspicious patterns and alert management.
- Smart contracts and governance: review of operational risks, roles, controls and documentation.
- Audit and continuous improvement: periodic reviews, corrective actions and up-to-date evidence.
If you need to put crypto compliance into practice, see our crypto legal services or, for an independent review, the external expert report.
Crypto in day-to-day operations
Crypto compliance: from "ticking the box" to controlling risk with evidence
An effective crypto compliance program is not a document: it is a set of repeatable decisions (on-chain KYC, Travel Rule, traceability, monitoring and escalations) with a full audit trail. Here is a visual overview of how it works in practice.
1) OnboardingCrypto KYC: on-chain + off-chain
Identification and verification adapted to digital assets: traditional documentation + wallet analysis, on-chain history and risk scoring.
- Identity verification
- Wallet analysis
- Crypto risk scoring
2) TraceabilitySource of funds: the fiat↔crypto bridge
Verifiable dossiers that combine on-chain analysis with off-chain documentation for banking access, audits and investors.
- On-chain analysis
- Off-chain documentation
- Consistent narrative
3) OngoingTravel Rule + on-chain monitoring
Data flows between counterparties, detection rules, mixers/bridges and alert management with a full audit trail.
- Travel Rule data sharing
- Detection of suspicious patterns
- Alert handling and closure
4) GovernanceMiCA, governance and audit
CASP license readiness, capital requirements, custody, internal governance and periodic audits of the compliance program.
Tip: governance, minutes, alert KPIs and role-based training are usually the first things supervisors ask for.
Quick decisionPractical crypto map: what to do at each risk level
Low risk
Standard KYC + basic wallet verification + periodic review.
Medium risk
On-chain analysis + Travel Rule + enhanced controls + evidence.
High risk
EDD + verified source of funds + internal escalation + intensive monitoring.
Crypto playbook
Crypto compliance in practice
On-chain/off-chain KYC
Identity verification + wallet analysis, risk scoring and periodic updates.
KYC file, wallet report, risk profile and review date.
On-chain traceability
Analysis of fund flows, identification of mixers/bridges and a verifiable narrative.
On-chain report, off-chain documentation, source-of-funds dossier.
Travel Rule
Sharing originator/beneficiary data with counterparties on a risk basis.
Transfer log, data shared, exceptions and justifications.
MiCA / CASP
Authorization, governance, capital, custody, transparency and internal policies.
Authorization application file, policies, contracts, controls and governance minutes.
Audit + improvement
Periodic program reviews, gap detection and corrective actions.
Audit reports, remediation plan, KPIs and evidence of improvement.
Typical red flags in crypto transactions
Indicators to adjust your controls and justify enhanced due diligence.
- Wallets linked to mixers, tumblers or obfuscation services.
- Fragmented transfers (structuring) or transfers with no clear economic rationale.
- Reluctance to provide KYC documentation or information on the source of funds.
- Transactions involving high-risk jurisdictions or jurisdictions with no crypto regulatory framework.
- Frequent changes of wallets or beneficiaries, or volumes inconsistent with the customer's profile.
Working glossary
Key concepts in crypto and blockchain
If you are implementing crypto compliance, these terms come up in audits, with regulators and in day-to-day operations. Understanding them well helps you design workable controls.
MiCAEU regulation
Markets in Crypto-Assets
EU regulation that sets the authorization, governance and compliance framework for crypto-asset service providers (CASPs).
Useful for: exchanges, custodians, token issuers.
CASPLicense
Crypto-Asset Service Provider
A provider of crypto-asset services subject to authorization and supervision under MiCA: exchanges, custodians, trading platforms and advisers.
Typical evidence: authorization application file + policies.
Travel RuleData
Crypto travel rule
The obligation to share originator and beneficiary data on crypto-asset transfers between service providers.
Typical evidence: transfer log + data shared.
On-chain KYCOnboarding
Crypto-adapted verification
Customer identification that combines traditional documentation with wallet analysis, on-chain history and risk scoring.
Key: wallet + identity + risk profile.
TraceabilityOn-chain
Fund flow analysis
Tracking the origin and destination of crypto-assets with blockchain analytics tools to document provenance and detect risks.
Typical evidence: on-chain report + supporting dossier.
Mixer / TumblerRed flag
Obfuscation service
Tools that mix transactions to make them harder to trace. Their use by customers is a red flag that calls for enhanced analysis.
E.g.: documented decision rationale + escalation.
DeFiWeb3
Decentralized finance
Financial protocols built on smart contracts without centralized intermediaries. They raise specific regulatory challenges in AML and governance.
Regulatory outlook: AMLR + MiCA 2.
Security TokenTokenization
A token that qualifies as a transferable security
A digital asset representing economic or governance rights comparable to those of a financial instrument. Subject to MiFID II and securities market rules.
Typical evidence: legal classification opinion.
Banking accessFiat↔Crypto
Access to banking services
The ability to work with banks while having exposure to crypto-assets. It requires traceability, a documented source of funds and verifiable AML controls.
Outcome: dossier + narrative + evidence.
Free resource · PDF
Download the 10-Step Crypto Compliance Checklist
The 10 controls that exchanges, custodians, token issuers and crypto projects must implement under MiCA, the AMLR and the Travel Rule, with the evidence expected for each one.
- The 10 steps of a crypto compliance program
- The evidence expected for each control (CASP / AML / Travel Rule)
- References to MiCA, the AMLR and Law 10/2010
- Professional PDF · 7 pages
No spam. Your email is only used to send you this checklist and, occasionally, relevant crypto regulatory updates (MiCA, AMLR, Travel Rule).
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