17-6-2025 – U.S.-based exchanges Coinbase and Gemini are on the cusp of securing approval to operate across the European Union, marking a significant step towards global expansion. According to Reuters, both platforms are poised to obtain the coveted Crypto-Asset Service Provider (CASP) licences under the EU’s Markets in Crypto-Assets (MiCA) framework, a comprehensive regulatory regime that took full effect late last year to harmonise oversight across the 27-nation bloc.
Gemini targets Malta, Coinbase chooses Luxembourg
Gemini, established by twins Tyler and Cameron Winklevoss, has set its sights on Malta, applying for its CASP licence in January 2025, a spokesperson confirmed to The Block. Malta, alongside Luxembourg, has emerged as a burgeoning hub for crypto approvals, having already greenlit licences for platforms like OKX and Crypto.com. Coinbase, meanwhile, is expected to secure its licence through Luxembourg, where it plans to establish a dedicated office, Reuters reported.
MiCA passporting spurs debate over regulatory arbitrage
Yet, the concentration of approvals in these smaller jurisdictions has sparked debate. Some experts warn of potential regulatory arbitrage, as MiCA’s “passporting” mechanism allows firms authorised in one EU state to operate across the entire bloc, despite varying national approval processes. The European Securities and Markets Authority has voiced concerns, particularly after the $1.5 billion Bybit hack earlier this year, with Maltese authorities defending their “expedited processing” as a product of deep regulatory expertise.
The MiCA framework, designed to standardise crypto regulation, has not deterred firms from seeking approvals beyond Malta and Luxembourg. BitGo, a crypto custodian, secured its CASP licence from Germany last month, while MoonPay and Hidden Road have gained approvals in the Netherlands, reflecting a broader distribution of regulatory pathways.
Gemini’s broader European strategy and public listing goals
Gemini, which is gearing up for a public listing, has also expanded its European footprint, having obtained an updated Virtual Asset Service Provider (VASP) licence in France in November 2024, aligned with Financial Action Task Force (FATF) standards. Unlike the MiCA-specific CASP, which governs a defined set of crypto services, the VASP designation focuses on global anti-money laundering compliance.
For Gemini, the EU is a cornerstone of its international ambitions, evidenced by the appointment of three senior executives to spearhead its European strategy.
