Stablecoin issuer / redeemer in Croatia

Current Regime (Pre-MiCA): Croatia operates a registration regime for VASPs, primarily for AML/CFT supervision. This means entities providing virtual asset services must register with the USPN and comply with AML obligations. It is not a full financial services license in the traditional sense, but an AML registration.

Future Regime (Post-MiCA): From December 30, 2025, MiCA will introduce a harmonized licensing regime across the EU. Entities providing "crypto-asset services" (as defined by MiCA) will require a license from a competent national authority (likely HANFA in Croatia, in coordination with USPN for AML aspects) in one EU member state, which will then allow them to operate across the entire EU ("passporting"). This will replace the national AML registrations for the services covered by MiCA.

Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1114 (Note: MiCA has a phased implementation, with most provisions for CASPs applying from 30 December 2025).

Croatian Financial Services Supervisory Agency (Hrvatska agencija za nadzor financijskih usluga – HANFA): While USPN handles the AML registration, HANFA, as the financial regulator, may also have a role in interpreting certain crypto-assets as financial instruments under existing securities laws, or in providing guidance, particularly concerning future MiCA implementation.

National Bank of Croatia (Hrvatska narodna banka – HNB): As the central bank, HNB monitors financial stability and may have views on crypto-assets impacting the traditional financial system.

Office for Anti-Money Laundering (Ured za sprječavanje pranja novca – USPN): This is the primary authority responsible for supervising the implementation of AML/CFT measures by obliged entities, including VASPs. They maintain the register of VASPs.

Generally, a legal entity incorporated in Croatia is required to apply for registration.

A registered office in Croatia is necessary.

VASPs are required to register with the Ministry of Finance – Financial Intelligence Office (Ured za sprječavanje pranja novca) as part of their AML/CTF obligations.

This registration requires compliance with the Croatian Anti-Money Laundering and Terrorist Financing Act (Zakon o sprječavanju pranja novca i financiranja terorizma), which transposes EU AML Directives (specifically AMLD5).

Implementing robust KYC/CDD (Know Your Customer/Customer Due Diligence) procedures.

Reporting suspicious activities to the Financial Intelligence Office.

Appointing an AML Officer.

Establishing internal AML policies and procedures.

Explicit national rules for the segregation of client crypto assets from the firm's own assets are not specifically detailed within the current AML/CTF framework.

There are no specific national insurance or bonding requirements explicitly mandated for crypto custody providers under the current AML/CTF framework.

There are no explicit national mandates for cold storage of crypto assets. Operational security measures, including the use of cold storage, are generally considered best practices for secure custody but are not yet regulatory requirements.

Custodial License Requirements (Under MiCA):