When founders start planning to obtain authorization as a crypto asset service provider (CASP), the conversation almost always reaches the same point: "So, do we need to hire a compliance officer?" Sometimes the next question follows: "And a Money Laundering Reporting Officer (MLRO)? Is that all?"

The answer to both questions is yes. But viewing these two roles as the ultimate goal is the most common and serious misconception about what MiCA actually requires from the compliance function.
Regulators do not check whether the organizational structure has the correct job titles. They assess whether the governing body as a whole has the knowledge, structural independence, and documented operational depth necessary to manage a regulated financial institution.
The MiCA license is not issued to an individual. It is issued to an organization.
It is this distinction that underlies why so many early-stage applications get stuck or require significant revisions before the national competent authority (NCA) grants approval.