AVERLOR
Applying for CASP Licence under MiCA—B2B & B2C Model
Executive Summary
Averlor.com is applying for authorisation as a Crypto-Asset Service Provider (CASP) under the MiCA framework.
The Company will provide regulated crypto-asset services to both retail and corporate clients, all subject to full onboarding and compliance procedures.
The business model is focused on core services, enabling clients to acquire, hold and transfer crypto-assets within a transparent and controlled environment.
The initial launch is intentionally simple, with a conservative risk approach and no additional or hybrid activities.
Services in Scope
Exchange of crypto-assets for fiat currencies
Exchange of crypto-assets for other crypto-assets (optional at launch)
Custody and administration of crypto-assets on behalf of clients
Transfer of crypto-assets on behalf of clients (subject to final scope confirmation)
The Company focuses on clearly defined and regulated crypto-asset services within the MiCA framework.
Client Segments
B2C — Retail Clients
Individuals
Full KYC Onboarding
Sanctions Screening
Ongoing Monitoring
B2B — Corporate Clients
Legal Entities
Full KYB Onboarding (Including UBO Verification)
Sanctions Screening
Risk-Based Monitoring
All clients are onboarded subject to AML/CFT requirements and internal compliance procedures.
Customer Journey
Onboarding
Client Registration (via Website/Platform)
KYC / KYB Verification
No actions available without verification
Funding
Client funds account via supported methods
Exchange
Client initiates crypto-asset purchase or sale
Custody
Crypto-assets are held on behalf of the client
Transfer
Client may instruct transfer of crypto-assets to a designated wallet or account
Risk & Compliance
Full KYC / KYB onboarding for all clients
Sanctions screening and PEP checks
Transaction monitoring and risk-based controls
AML/CFT policies and compliance procedures
Restricted jurisdictions policy
Ongoing compliance monitoring
The Company applies a conservative risk approach and adheres to applicable AML/CFT regulatory requirements.
Architecture
Client Interface
web platform
Account & Wallet Management
Execution Engine
order processing
Compliance & Monitoring Layer
Secure Infrastructure & Data Protection
The platform is designed with a controlled and secure architecture, ensuring operational oversight, monitoring and protection of client-related processes.
Governance & Team
Shareholders & Directors — Residents of Latvia
Jevgenijs
Strutinskis
Education
Riga Technical University
Bachelor's Degree in Railway Transport Engineering
Specialist Degree in Railway Transport Logistics
Financial audit — 5 years (Latvijas Dzelzceļš)
Experience in Blockchain, Cryptocurrency, and Mining
CEO of a Tech and Payment Solutions Integration Company, SIA INSYNK
Bella
Džamaldajeva
Education
University of Greenwich, London
BSc Psychology with Counselling
MSc Forensic Psychology
HR & Accountant at SIA INSYNK
Manager & Accountant at Restaurant ROI
Recruitment, onboarding, and employee lifecycle management
Financial reporting, invoicing, and month/year-end closing support
Team
A team of 16 professionals with experience in fintech and blockchain, with strong expertise in technical integrations, risk management, and vulnerability assessment.
16
Professionals
Capital & Ownership
Initial Capital: EUR 150,000
Co-founders are Latvia-based, Latvian citizens
ensure local management and operational oversight
Fully funded by shareholders
Transparent source of funds
Founders as co-owners and active managers
Clear and simple ownership structure
The Company maintains a transparent ownership structure with fully verifiable source of funds.
NEXT STEPS
Confirm the proposed regulatory scope
Validate the business model and service structure
Support preparation of the CASP authorisation application
Advise on regulatory and compliance framework
Provide guidance on implementation to ensure regulatory alignment
The Company is prepared to proceed with the authorisation process with professional legal support.