Taking over clients of crypto firms without a MiCA licence

Taking over clients, not buying the company

Electrocoin does not need to buy any of the firms left without a licence. It is enough for their clients to open an account with Electrocoin and transfer their assets. Buying a firm would bring no regulatory benefit: Hanfa grants authorisation to an individual company, so the licence does not transfer with a purchase⁵, and Electrocoin already holds one anyway². Buying the firm would also mean taking on its liabilities and risks.

• What is taken over: clients and their assets, with each client's consent. Client data may only be transferred on a legal basis under the GDPR, and the safest one is the client's consent⁶.
• Why the firms would cooperate: ESMA requires firms leaving the market to have an orderly wind-down plan, to notify clients in advance and to transfer their assets to a licensed provider or to the client's own wallet⁷. Electrocoin can be that licensed provider.
• A real-world example: Hanfa ordered Fima Plus to notify its clients within 8 days that its services were ending and to ask for instructions on returning their assets. This involved 123 clients with assets of around $484,000⁸. That is the moment when a client chooses a new platform.

Firms without a licence: how big they are

Services as listed in Hanfa's register¹. For comparison, in 2025 Electrocoin had €1.18M in net revenue and 29 employees²¹. Firms book revenue in different ways: some gross (the value of crypto sold), others only the commission. That is why their revenue is not directly comparable with Electrocoin's.

How to take over clients: a five-step plan

1. 1.

   Direct contact with management

   Approach the firms that have clients (Blok Be, FiatBit, Cana Pay, M obrada, Fintrax, DUPLICO) and offer Electrocoin as a licensed provider to which they can refer their clients. For the firms, this settles the orderly wind-down obligation that ESMA requires⁷.

2. 2.

   Client referral agreement

   The firm sends its clients a notice recommending Electrocoin, and each client gives consent and opens an account themselves⁶. The firm can receive a one-off fee for each client who switches. The amount of the fee is a matter for negotiation.

3. 3.

   An easy switch

   Registering with Electrocoin takes about 8 minutes, with a 30-second video check, and crypto can be deposited from another wallet²⁵. Clients who switch need a dedicated page with instructions and personal support in Croatian.

4. 4.

   "Switch to the first Croatian licensed platform" campaign

   Large exchanges are already doing this: OKX gives an 8% bonus on transferred assets, Coinbase 5%, SwissBorg 3% on transfers from unlicensed exchanges, and Kraken ran a one-million-euro prize draw²³²⁴. Electrocoin probably cannot afford such percentages on a margin of 1–2%²². A few months with no margin or a smaller fixed bonus is more realistic.

5. 5.

   Retention

   A client taken over is only worth something if they stay. Large clients, e.g. those who traded OTC with Blok Be⁹, need a personal contact, and everyone else regular perks.

Estimate: additional monthly turnover and revenue

How revenue is calculated. Electrocoin earns a margin of 1–2% per transaction²². The margin is charged both when a client buys crypto for euros and when they sell it back for euros. Example: a client buys bitcoin for €1,000 and later sells it for €1,000. Turnover is €2,000, and Electrocoin earns €20–40, i.e. 1–2% of turnover.

Starting point. The number of clients these firms have is not public, so we use their revenue from Fina as a measure of their annual turnover. This is a lower bound, because firms that book only commission have actual turnover many times higher than their revenue. We count the eight firms that have revenue: Moneysail, Blok Be, Cana Pay, FiatBit, M obrada, Fintrax, DUPLICO and BD Innovation Hub. In total €21.3M a year, around €1.78M a month^{1011121314151617}.

Revenue = turnover × 1% (lower value) to turnover × 2% (upper value). All amounts are estimates.

What this means for Electrocoin: net revenue in 2025 was €1.18M, around €98,000 a month²¹, and we estimate turnover at around €4.9M a month²⁶. Taking over 50% of clients would bring around 18% more turnover and 9–18% more revenue. The domestic unlicensed firms are small relative to Electrocoin, so this proposal is worthwhile as a quick and cheap add-on, but not as a main source of growth.

Risks and open questions

• The number of clients and the assets of these firms are not public. The estimate can only be refined after talks with management.
• Part of the firms' revenue, e.g. at DUPLICO and Cana Pay, may not come from crypto.
• Clients may also go to large exchanges offering 3–8% bonuses²³.
• Moneysail is subject to Hanfa supervisory measures from 2024²⁷, so any cooperation with it needs separate checks.