Because the regime is activity-based, the first task for any firm is decomposition: separating a single commercial proposition into the regulated activities it actually performs.
Decomposing the operating model
A venue that also holds client assets and facilitates issuance is performing at least three distinct activities, each with its own authorisation pathway, conduct expectations and reporting profile. Treating the proposition as one thing is the most common structural error we observe.
“Authorisation follows activity, not branding.”
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