Looks Like I Called the Crypto License Race Right
I was scrolling through crypto news this morning when I spotted something that made me sit up straight. Gemini and Coinbase are both getting their EU licenses — but guess where they’re going?
Gemini’s headed to Malta. Coinbase picked Luxembourg.
And apparently Ireland, which used to be the go-to destination for crypto companies, has basically fallen off the map after their central bank governor called crypto a “Ponzi scheme” last year.
I feel slightly vindicated right now, because just yesterday I was defending Malta against all the criticism about our “too fast” licensing process. All these complaints from France about regulatory shopping and races to the bottom — turns out companies are actually making strategic choices about where to get licensed based on real factors.
The Gemini decision especially caught my attention. They’re going with Malta even though we’re apparently moving “too quickly” according to some EU regulators. Malta’s already approved OKX and Crypto.com within weeks of MiCA taking effect, and now we’re adding another major player to the list.
Meanwhile, Coinbase chose Luxembourg — a country known for being incredibly cautious about finance. They’ve got 200 employees across Europe and plan to add 20 more in Luxembourg specifically. Their spokesperson mentioned they see Luxembourg as “a strong financial hub” and are committed to “safe, compliant operations.”
The contrast is interesting. Two major crypto companies, both need EU access under MiCA, but they picked completely different strategies. Gemini went with the country that moves fast, Coinbase went with the one that moves carefully.
But what really stands out is how Ireland lost this game entirely.
Ireland used to be a favorite for crypto firms. English-speaking, EU member, established financial sector — seemed perfect. Then Gabriel Makhlouf, their central bank governor, started calling unbacked crypto “essentially a Ponzi scheme” in early 2023. He said crypto has “no social value whatsoever” and pushed for banning crypto advertising to young adults.
According to the article I read, that basically killed Ireland’s appeal for crypto companies. They started looking elsewhere, “even if the process is slower.” One comment from a central bank governor managed to tank an entire industry’s interest in a country.
That’s wild when you think about it. Ireland had all the advantages — language, legal system, financial infrastructure. But perception matters just as much as practical benefits. If the head of your central bank is publicly calling your industry a scam, why would you want to set up shop there?
This connects to what I wrote about Malta yesterday. All those complaints about us moving too fast with crypto licenses — maybe speed is actually a feature, not a bug. Companies want regulatory clarity, and they want it quickly. The European Securities and Markets Authority is apparently reviewing Malta’s licensing process and will release a report soon, but honestly? The market seems to be voting with its feet.
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Gemini could have chosen any EU country for their license. They picked Malta. That suggests our process works, even if other regulators think we’re being too aggressive.
The Luxembourg choice for Coinbase makes sense too, but for different reasons. They’re a massive US company with regulatory scrutiny back home. They probably want the most conservative, bulletproof licensing they can get. Luxembourg gives them that reputation for caution and thoroughness.
Different companies, different strategies. But both chose countries that gave them what they needed efficiently.
France keeps talking about regulatory shopping like it’s automatically bad. But isn’t this just how markets work? Countries offer different approaches, companies choose what fits their needs best. If France wants more crypto companies choosing French licensing instead of ours, maybe they should make their approval process more attractive instead of complaining when others do it better.
The timing here is pretty perfect too. Malta’s been building our crypto framework since 2017 with the VFA regulations. We put in the groundwork early, and now we’re seeing the benefits as MiCA rolls out across the EU. Companies like Gemini already had relationships with our regulators, so the transition to MiCA licensing was smoother.
Ireland had similar early advantages but apparently threw them away with public comments that spooked the industry. Luxembourg never tried to be a crypto hub but maintained their reputation for financial thoroughness, which appeals to larger, more cautious companies.
The ESMA review of Malta’s process will be interesting to watch. If they find problems, that could slow things down. But so far, the companies we’ve licensed seem to be operating fine. OKX got fined €1.2 million for AML violations after their approval, but that actually shows our oversight is working — we caught issues and took action.
What strikes me most is how this validates the argument I made yesterday about competition between EU countries. Malta offers speed and clarity. Luxembourg offers caution and conservatism. Ireland… well, Ireland offered skepticism and got exactly what you’d expect from that approach.
Companies are making rational choices based on what each country provides. That’s not regulatory shopping — that’s just good business strategy.
Maybe France and the other countries complaining about Malta’s pace should focus less on criticizing us and more on figuring out what they can offer that we can’t. Because right now, it looks like we’re giving crypto companies exactly what they want: clear rules implemented quickly by regulators who understand the industry.
The Gemini decision suggests that despite all the criticism, Malta’s approach is working. And the Coinbase choice shows there’s room for different strategies across the EU. Some companies want speed, others want ultra-conservative safety.
Both can coexist under MiCA. The companies get what they need, the EU gets comprehensive coverage, and countries can compete on the quality of their regulatory services.
Seems like a pretty good outcome to me.
What do you think about companies choosing different EU countries for crypto licensing? Is this healthy competition or problematic regulatory shopping? Drop a comment with your take.
