Buying a ready-made licensed VASP company is marketed on a promise of speed: "don't wait for a licence — buy a company that has one." The story on this page is different and more precise: a licence belongs to the legal entity, so a share deal does indeed buy the company with its licence — but in every serious regime the change of ownership control is itself a regulated transaction. It requires the regulator's prior consent or a notification, and the buyer is screened with the same logic applied to a fresh applicant. The M&A route saves time only when it is built as a regulatory process from day one.
That is exactly what our M&A service is: simultaneous management of all three rings — due diligence, regulatory consents and the transaction contract — so that the deal does not collapse at the stage where it most often collapses: the consent. Below: facts confirmed per regime, the due-diligence checklist and the Georgian layer.
A Change of Control Is a Regulated Transaction
In the MiCA space this frame is written into the regulation itself: the authorisation application (Article 62) requires checks on the management body and on qualifying shareholders — ten percent or more (Article 3(1)(36)) — and an acquisition comprising a qualifying holding re-runs those checks on the new owner. CySEC's fee schedule prices this process in euros: a proposed acquisition of a CASP — EUR 8 000 per proposed acquisition (Article 83), and a change of the management body — EUR 2 000 per change (Article 69). In the Czech Republic, since August 2025 only legal entities may provide MiCA services — so the buyer's legal form is itself a precondition of the decision.
Non-EU regimes follow the same logic. In Serbia the NBS issues consents for the appointment of management members and directors and for acquirers of a qualifying holding — with AML screening of the origin of funds and flags for offshore or high-risk exposure. In Armenia the central bank's (CBA) prior consent is required for the acquisition of a qualifying holding, and the decision must be taken within one month (Article 28). So wherever a "fast entry without the regulator" is being sold, what you actually have is a deal that cannot close without consent — and a deal closed without consent is itself a breach of the rules.

