“Can an institutional crypto custodian survive MiCAR by re-platforming as the pure infrastructure layer that licensed VASPs and banks run their custody, staking and prime-brokerage services on?”
Finoa launched in 2018–2019 as a BaFin-regulated institutional crypto custodian for European asset managers, family offices and VCs, positioning against Anchorage, Coinbase Custody and BitGo. By 2026 the company has explicitly repositioned itself as a pure 'technology infrastructure provider' — Finoa GmbH is no longer an authorised Crypto-Asset Service Provider under MiCAR, does not custody assets or execute orders, and instead licenses its custody/staking/prime-brokerage tech (Finoa Technical Services, Finoa Consensus Services) to regulated VASPs that hold the licences. The strategic bet is that MiCAR-era custody is a plumbing layer for licensed banks and VASPs, not a direct-to-institution service.