We advised Noah LV on obtaining a CASP (MiCAR) licence and a PI licence in Latvia, supporting the client through a dual authorisation process for its planned crypto-asset and payment services activities. The engagement covered the preparation for pre-licensing stage, coordination and finalisation of both licensing packages, as well as the broader regulatory readiness work needed to support the client’s market entry and operating model and the establishment of the entity in Latvia.
Noah is a London‑headquartered international fintech group building payment infrastructure that connects traditional money and stablecoins, with regulated operations in the United States (17 state Money Transmitter Licences) and Canada (Bank of Canada‑approved Payment Service Provider). The company has raised tens of millions of US dollars and is backed by leading investors including LocalGlobe, Felix Capital and FJ Labs, as well as the former CTO of Adyen and the founders of Palantir and Skype. Noah partners with major industry players such as Circle, Opera’s MiniPay and Ledger to bring regulated EUR accounts and stablecoin payment rails to millions of users globally.
This matter stands out because the client successfully obtained two licences in Latvia within a notably short timeframe. Following submission, the CASP package led to the licence being granted within 2 months and 13 days, while the payment institution package led to the licence being granted within 1 month and 6 days. The matter was also notable in the context of the crypto-asset market, as it was the fifth licensing-out transaction out of 11 handled by Sorainen in this area. The matter therefore highlighted not only the scale and complexity of the underlying regulatory work, but also the team’s ability to manage a fast-moving, multi-workstream licensing process efficiently and strategically. The engagement also gained public visibility through the announcement that Latvijas Banka granted Noah LV SIA two licences, underlining the significance of the project in the Latvian financial and crypto-asset regulatory market.
Our involvement
We supported the client throughout the preparation, review and finalisation of the licensing documentation for both the CASP (MiCAR) and PI authorisation processes. Our work included advice on the business plan, application forms, governance framework, AML and sanctions policies, customer due diligence and monitoring procedures, safeguarding and wind-down documentation, prudential materials, terms of service, and a broad set of ICT, information security, continuity and resilience policies. We also advised on management body and MLRO suitability matters, investor-related documentation, operational and corporate structuring questions, coordination with Latvijas Banka, responses to regulator questions, and the practical aspects of filing the applications and managing the document submission process from submission through to successful authorisation.
The team included partners Ramona Miglāne and Linda Sarāne-Reneslāce, counsels Andis Burkevics, Santa Rubīna and Inese Heinacka, of counsel Mārtiņš Rudzītis, senior associates Jevgēnija Ziņģe, Agneta Rumpa and Edvīns Draba, associates Imants Kreičmanis, Juris Steņins, Krišjānis Cercens and Elīza Marija Roshofa, and assistant lawyers Evija Velvele, Annija Kuzma and Annika Līze Valtere.
Evija Velvele and Imants Kreičmanis played a leading role in the day-to-day execution of the matter, coordinating the main workstreams, managing the preparation and submission of licensing documentation, and ensuring the efficient progression of both licensing processes through to successful authorisation.
