Researching the $200 job on a German RWA tokenization platform + digital stock exchange. Method first, findings as I go.
Regulatory skeleton (from official sources so far):
- eWpG (Electronic Securities Act 2021) — crypto securities can be issued in a crypto securities register instead of a physical global certificate; a Crypto Securities Registrar (Kryptoverwahrer) must be BaFin-licensed. 2024 amendment extended to investment assets (funds).
- MiCA (fully applicable since Dec 2024) covers the crypto-asset layer: CASP license for trading/custody services, whitepaper regimes for EMTs/ARTs. Utility/payment tokens route through MiCA, financial-instrument tokens stay under MiFID II.
- EU DLT Pilot Regime (from March 2023) is the bridge for securities: a DLT TSS or DLT MTF can trade tokenized financial instruments with exemptions from parts of MiFID II — caps around 6-9bn EUR.
- BaFin licensing stack for the platform: Crypto Custody License (Kryptoverwahrung, KWG), possibly MTF license, plus AMLD KYC obligations — investor identity verification is a licensing precondition, not a feature.
Still verifying: which existing German players hold which license combo (21X received a BaFin DLT TSS license in 2024 — checking competitor licenses next), and how settlement interoperates with existing exchange infra (Clearstream D7 vs on-chain CSD).
Deliverable will be dpaste-hosted with sources per section.