Most people holding Strategy’s 11.5% dividend-paying STRC, are making a strange bargain with the company; that on monthly snapshot days, the stock will trade near the company’s intended $100 share price.

In between those dates, however, STRC invariably wanders downhill. Indeed, it closed yesterday at $91.79, 8.2% below its target.

Strategy persuades buyers to take the bargain of downside possibility on their investment with an above-market yield of 11.5%.

Strategy, the bitcoin (BTC) treasury company built by Michael Saylor, markets STRC as a near-$100 instrument that strips away BTC’s volatility, providing ostensibly predictable payouts and a USD-stable target.

Anyone who holds STRC at the close of Nasdaq’s regular trading session on the dividend record “snapshot” date receives that payout. 

Because Strategy pays a dividend on the full $100 par regardless of its price on Nasdaq, the company designed STRC to hold near $100 on its snapshot dates.

The actual chart of Nasdaq trades, unfortunately, says otherwise.

STRC had its IPO in July 2025 and didn’t even trade up to $100 until October. For over a trailing month as of publication time, STRC hasn’t traded at or above $100.

STRC crashes ex-dividend

The morning after its snapshot date, the stock trades “ex-dividend,” and holders earn nothing extra for maintaining their investment until another two weeks transpire and another snapshot occurs.

Predictably, the stock always rallies into these snapshot dates and immediately sells off afterward. 

Historical prices bear this out across the security’s short life.

In August 2025, STRC dropped to $92.20 in-between its dividend snapshot dates. 

In September, it drifted to $96.61. October was a similar $96.75. Then November frightened investors with a 9.5% drop from $100 to $90.52.

Although each month’s trading range is unique, this month is risking becoming on of its worst. Just yesterday, shares closed at $91.79.

Run-ups into the dividend snapshots are routine, but declines are just as routine.

China’s central bank leadership has called for tighter attention to stablecoins as privately issued tokens increasingly intersect with cross-border payments and aspects of the international monetary system. In remarks reported by The Paper, Wang Xin, director general of the Research Bureau at the People’s Bank of China (PBOC), urged regulators to monitor stablecoin-driven developments while strengthening international coordination and regulatory cooperation.

The comments also pointed to broader risks regulators associate with payments infrastructure—namely growing uncertainty and the possibility that payment channels could be used in ways that disrupt cross-border transactions. While Wang did not announce new rules or endorse stablecoins, the message aligns with a more restrictive regulatory posture toward private digital money and highlights how compliance requirements could expand for firms operating across jurisdictions.

Key takeaways

• China’s PBOC leadership urged authorities to closely monitor stablecoins’ impact on cross-border payments and the international monetary system.
• Wang Xin warned about uncertainty and potential “weaponization” of payments that could disrupt normal cross-border activity.
• The remarks come after China and multiple agencies previously banned unauthorized renminbi-pegged stablecoins and tokenized real-world assets (RWA) without government approval.
• Wang also flagged central bank digital currencies (CBDCs), saying cross-border CBDC roles warrant similar scrutiny and improved policy coordination.

Stablecoins under PBOC scrutiny: focus on cross-border payment architecture

According to The Paper, Wang Xin said regulators should pay attention to whether stablecoins could assume a larger role in cross-border payments and consider how regulation and international coordination should proceed. The framing is notable because it treats stablecoins not only as a market asset class, but also as potential payment rails that can influence cross-border settlement behavior and, indirectly, monetary and financial stability concerns.

For institutional compliance and risk teams, this matters because cross-border payment use-cases can change a token’s regulatory treatment. Firms that interact with stablecoins—whether as counterparties, liquidity providers, or gateways—may face increased scrutiny around licensing, sanctions controls, and anti-money laundering (AML) and know-your-customer (KYC) obligations depending on the jurisdiction and the nature of the settlement flows.

Wang’s remarks also referenced risks linked to the governance and security of payment systems. In particular, he cautioned that uncertainty and potential weaponization of payments could interfere with ordinary cross-border transactions. While the statement did not specify mechanisms or actors, it reinforces the policy view that stablecoin-based payment networks could be exposed to geopolitical and operational disruptions.

Regulatory context: China’s earlier ban on unauthorized RMB-pegged stablecoins

Wang’s call for closer monitoring follows enforcement actions and rulemaking that have already restricted stablecoin issuance connected to the renminbi. Months earlier, the PBOC and seven other Chinese agencies banned unauthorized issuance of renminbi-pegged stablecoins and tokenized real-world assets on Feb. 6, according to reporting referenced in the underlying coverage.

As described in the broader record of that regulatory action, the rules were not limited to a single geography: they applied to both foreign and domestic entities and covered onshore and offshore versions of yuan-pegged tokens. The framework required issuers to obtain government approval, reflecting China’s preference for state-controlled digital money rather than privately issued digital currencies.

From a compliance perspective, the enforcement logic is significant. When regulators move from general warnings to binding restrictions tied to authorization, firms must assess where their activities sit in relation to “issuance,” “promotion,” “distribution,” and “use.” In cross-border operations, where marketing and technical access can be fragmented across countries, even indirect participation may raise questions about whether a firm is facilitating prohibited activity.

Broader implications for CBDCs and international coordination

Alongside stablecoins, Wang reportedly said central bank digital currencies (CBDCs) should also be observed more closely in relation to cross-border payments, with improved policy cooperation. This suggests China’s regulatory attention is not limited to private stablecoin markets; it also extends to how state digital currencies could influence international settlement.

The distinction is important for institutions evaluating future settlement models. If regulators view CBDCs as a more controllable alternative to private tokens for cross-border payment flows, then international coordination discussions could eventually translate into standards for interoperability, governance, or compliance expectations. Until those standards are defined, firms face uncertainty over how cross-border “digital money” will be regulated across legal regimes.

Additionally, China’s emphasis on international coordination underscores the inherently cross-border nature of stablecoin risk. Tokens can be transferred globally, but regulatory responsibility remains jurisdictional. This mismatch is a key reason why policy makers across regions increasingly tie stablecoin oversight to existing frameworks—such as AML/KYC expectations, licensing for payment or financial services, and controls aligned with sanctions and illicit finance prevention.

Stablecoin growth and compliance pressure from expanding usage

The PBOC’s renewed attention arrives as stablecoins continue to expand in market activity. The coverage referenced data points indicating that stablecoin supply increased and that stablecoins represented a substantial portion of overall crypto trading volume during the first quarter of 2026. It also noted that transaction volume can be heavily influenced by automated activity, with bots generating a large share of volume in that period.

While market statistics do not determine the legality of a token, they often influence supervisory priorities. Higher usage can increase the probability that compliance failures—such as inadequate customer screening, weak transfer controls, or unclear source-of-funds checks—are noticed by regulators and addressed through enforcement or additional requirements.

Institutional actors should also consider how major regulatory approaches are evolving elsewhere. In the European Union, for example, the Markets in Crypto-Assets (MiCA) framework provides a structured pathway for stablecoin-related obligations, including rules designed to mitigate risks from reserve management, disclosures, and operating conditions. Differences between regimes can create friction for cross-border service providers, particularly those offering custody, exchange, remittance, or settlement tooling connected to stablecoin flows.

Against this backdrop, China’s stance—requiring approval for renminbi-pegged stablecoins and tokenized RWA issuance—illustrates one end of the policy spectrum: a preference for tighter state oversight over private issuance. Even where stablecoins are used in ways not directly tied to issuance, the regulatory focus on cross-border payments signals that regulators may still scrutinize service layers around distribution and transfer.

Closing perspective: what to watch next

Wang Xin’s remarks do not announce immediate policy changes, but they reinforce an enforcement trajectory in which stablecoins and CBDCs are treated as strategic issues for payments governance and international coordination. For regulated firms, the near-term priority is to monitor how Chinese guidance develops and how cross-border compliance expectations evolve alongside international policy frameworks—especially regarding AML/KYC controls, authorization boundaries, and controls that address payment-system geopolitical and operational risks.

Order flow trading is the analysis of real-time buying and selling activity to understand how market participants interact and where prices may move next. It focuses on executed orders, resting orders, liquidity, volume, and market participation. This shows the activity behind price moves, not just the moves themselves. Its purpose is to help traders identify potential trades, assess market sentiment, and make trading decisions.

Traders apply order flow analysis across forex and CFD markets. This article explains how order flow works, its components, and three order flow trading strategies.

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What Is Order Flow Trading?

Order flow trading is a method that uses the analysis of executed trades, pending orders, liquidity, and volume to understand market participation and anticipate potential price movements. Applying order flow in trading involves examining where buy and sell orders might rest in the market.

To implement order flow analysis, traders focus on three components: liquidity, supply and demand zones, and trade execution.

Liquidity is the pool of resting orders waiting to trade at each level. These orders form supply and demand zones, where buying or selling has concentrated. Trade execution occurs when incoming orders meet that liquidity, and the balance between the two drives price discovery.

Much of the trading volume comes from banks and funds, so reading institutional trading activity adds context that price alone cannot give.

Order Flow vs Volume Analysis vs Price Action

Order flow, volume and price action describe market activity at different depths.

Price action reflects the shape of past price on a chart. Volume shows how much traded. Order flow shows the orders behind that trade. Order flow gives the most detail of the three.

Price action shows what happened. Volume tells you the size of activity but not its direction or intent. Order flow adds that missing layer. It shows whether buyers or sellers were the aggressors and where liquidity zones build up.

	Price action	Volume analysis	Order flow Advertisement
Measures	Price movement over time	Quantity traded	Orders behind each trade Advertisement
Shows	What price did	How active the move was	Who was aggressive, where liquidity sits Advertisement
Common tools	Candlesticks and chart patterns	Volume bars, volume profile	Footprint charts, DOM, cumulative delta Advertisement
Limitation	No trade size	No direction or intent	Complex Advertisement

Tools such as volume profile, Volume-Weighted Average Price, Volume-Weighted Moving Average sit between volume and order flow analysis, mapping volume across price to hint at order concentration. The practical trade-off is depth of insight against complexity. Order book analysis is the most detailed but also the hardest to read.

Core Components of Order Flow Analysis

In the realm of trading, dissecting the order flow is akin to peering into the heart of the market, revealing the intentions of traders through the movement of buy and sell orders.

The sections below cover the main chart components in order: order blocks, market structure and trends, imbalances, and volume. The commonly used order flow tools then follow, namely footprint charts, depth of market (DOM), also called market depth, and cumulative delta, alongside the volume profile.

Understanding these components allows traders to interpret order flow directly from the chart, providing insights into where the market might head next based on past and present trader actions.

Order Blocks (Supply and Demand Zones)

In analysing order flow on a chart, order blocks, or supply and demand zones, appear as areas where price action has shown significant movement away from a particular level, indicating a concentration of buy (demand) or sell (supply) orders.

These zones are typically highlighted by a sudden surge or drop in price, leaving behind a footprint where future price often reacts. For example, a demand zone might be identified by a rapid price increase from a specific area, suggesting buyers overpowered sellers significantly.

An order block marks where unfilled orders cluster, forming dense liquidity zones before a sharp move. When price revisits these supply and demand zones, those resting orders can absorb or repel it, which is why the area often produces a reaction. Blocks left by institutional trading activity tend to be the clearest.

Market Structure/Trends

The market structure, or trend, is visible through the series of highs and lows on a chart. An uptrend is recognised by ascending peaks and troughs, while a downtrend is marked by descending peaks and troughs. These structures show order flow traders the prevailing direction of market sentiment.

Trend continuation is central to market structure trading. In an uptrend, buyers repeatedly absorb supply at higher levels, and each higher low marks a fresh trading imbalance in their favour. In a downtrend, sellers repeatedly absorb demand and push prices lower, while each lower low signals a fresh supply–demand imbalance in their favour.

That imbalance has to persist for the trend to hold. When opposing flow takes over, the run of higher highs or lower lows breaks, which often signals a shift in market structure rather than a pause.

Imbalances

Imbalances manifest as large, directional candles that break away from a consolidation area, signifying a sudden imbalance between buyers and sellers. These are often accompanied by increased volume, which may suggest a strong commitment from traders to move the price in a specific direction.

In ICT and order flow terminology, this kind of gap usually appears in the form of a fair value gap. It forms when price moves so fast that one side barely trades, leaving a three-candle gap where little business was done. Traders mark these gaps because price often returns to fill them, rebalancing the orders that were skipped. A trading imbalance that stays unfilled can act as a magnet for future price, while one that fills cleanly tends to confirm the move that created it.

Volume

Volume is directly observable on a chart, usually depicted as bars beneath the price action. High volume bars accompanying significant price moves validate the strength of that move, implying a robust interest from the market in that price level. Conversely, low volume may indicate a lack of conviction, suggesting that the price move may not be sustainable.

Volume confirmation and order flow confirmation differ. Volume shows how much traded, confirming a move had participation behind it, but not who was in control. Order flow confirmation goes further, showing whether buyers or sellers were the aggressors at each level. A volume profile bridges the two by mapping where volume built up across price, though only footprint and delta data confirm the direction of that activity.

Footprint Charts and Cumulative Delta

A footprint chart shows the volume traded at the bid and at the ask inside each price bar. It reveals who was aggressive at every level, not just where price closed. Cumulative delta then tracks the running net of that buying against selling, turning the detail into a single trend line.

Bid and ask volume sit at the centre of this. Volume traded at the ask comes from aggressive buyers lifting offers. Volume traded at the bid comes from aggressive sellers hitting bids. Delta is the difference between the two within a bar, a positive figure when buyers dominate and a negative figure when sellers do.

Cumulative delta adds each bar’s delta to a running total. A rising line shows net buying building over time, while a falling line shows net selling. The most watched signal is divergence. If price makes a new high but cumulative delta does not, the buying behind the move may be weakening. Footprint and delta data are standard in centralised futures markets, where every trade is recorded at the exchange, which is why they appear so often in order flow study.

Depth of Market (DOM)

The depth of market, or DOM, is a live ladder of buy and sell orders waiting at each price. It is also called the order book, or market depth. The bid side lists resting orders to buy below the current price. The ask side lists resting orders to sell above it. The size at each level shows where liquidity is stacked.

Reading this ladder, sometimes called DOM trading, is a form of order book analysis that aids short-term price discovery. A centralised exchange shows the full depth of the market. OTC forex does not, because there is no central book and each broker sees only its own flow. This is the main limit on order flow trading in forex, which pushes traders toward liquidity and supply-demand methods, or toward futures data as a proxy. Even on exchanges, book depth alone can read liquidity incompletely.

Interested readers can learn more about these components and how they interact with each other in our comprehensive article on order flow analysis.

Order Flow Trading Strategy Examples

Let’s now take a look at how these components can be used in three order flow trading strategies.

The three examples below are educational illustrations of how order flow concepts fit together. They are not trading recommendations, and no setup works every time. Each one shows how tools such as order blocks, liquidity and moving averages might combine in an order flow trading strategy. Any approach can be tested on a demo account.

If you are ready to try these approaches on live markets, you can consider trading with them on FXOpen’s TickTrader platform.

Liquidity Sweep at Order Block/Supply or Demand Zone

A liquidity sweep is a quick push past an obvious high or low, where stop orders and breakout orders rest, followed by a sharp reversal. The move taps that pooled liquidity, fills large orders against the crowd, then turns. Spotting the sweep and the snap-back is what separates this setup from a plain breakout.

The concept of a liquidity sweep within an order block stands out for its nuanced approach to capitalising on market reversals. This strategy hinges on the premise that price movements in these critical zones often preclude a significant direction change, making them ripe for reversal entries.

However, while leaving a simple limit order at these areas may be tempting, unforeseen news or a strong trend can cause the price to trade beyond it. Therefore, the theory states that looking for confirmation is important. Using the idea of a liquidity sweep or a bull/bear trap, traders can identify higher probability setups in these areas.

Entry

• Traders typically identify an order block, marking zones that prompted a significant imbalance and strong directional price move.
• Watching for the price to approach these zones is important, with a keen eye on the price action within the zone for signals of a potential reversal.
• The formation of new highs in a supply zone or lows in a demand zone accompanied by a liquidity sweep (a brief breach of these highs/lows followed by a quick return) might serve as a trigger for entry.
• The appearance of reversal patterns, like a shooting star, hammer, or engulfing candlestick, may indicate the market’s rejection of prices beyond the zone.

Stop Loss

• Traders could place a stop loss just beyond the boundary of the supply or demand zone.

Take Profit

• Profit targets might be set at the nearest opposing supply or demand zone, usually where another significant imbalance lies.

Moving Average Crossover at Order Block/Supply or Demand Zone

Integrating moving averages into the analysis of order blocks or supply/demand zones offers traders a quantitative lens through which market sentiment can be gauged more precisely. This strategy particularly revolves around the utilisation of two moving averages.

We’ve used Exponential Moving Averages (EMAs) with periods of 9 and 20, leveraging their sensitivity to price movements to identify potential reversal points within these critical market zones. However, traders can use whichever type or length they prefer, though a balance should be struck between responsiveness and mitigating false signals.

Note that moving averages are confirmation tools here, not order flow indicators. They read prices, not orders, so they confirm an order flow signal at the zone rather than generate one.

Entry

• The trader identifies an order block where a substantial move has previously occurred, leaving behind a noticeable imbalance in the price chart.
• As the price revisits this zone, attention is directed towards the EMAs’ behaviour. For instance, a crossover of the 9-period EMA above the 20-period EMA signals bullish momentum, whereas its crossover below the 20-period EMA reflects bearish momentum.
• Entry might be considered once the moving average crossover aligns with the anticipated direction of the reversal, indicating a strengthening trend.
• This signal might be further validated if accompanied by a liquidity sweep or specific candlestick patterns within the zone.

Stop Loss

• A stop loss could be placed beyond the zone’s extremes.
• Given the added confidence from the moving average crossover, the stop loss could also be positioned just beyond the most extreme high or low when the price entered the zone.

Take Profit

• The take-profit target might be set at an opposing supply or demand zone. Such zones are anticipated to act as natural barriers where the next significant price reaction could occur.

Impulse and Correction Stop Order

The Impulse and Correction Stop Order strategy leverages the dynamic reaction of prices at supply or demand zones, focusing on the price action that follows these pivotal areas.

Recognising that initial reactions from these zones can be sharp, signalling strong market rejection, this approach waits for a pullback or correction as a secondary entry point. This method is popular among traders looking to capitalise on the momentum shift or those who may have missed the primary reversal within the zone.

An impulse is the first sharp move out of a zone, where one side overwhelms the other. The correction is the slower pullback that follows, as price drifts back toward the zone. Often it refills the trading imbalance left by the impulse, trading through the gap the fast move skipped. That refill is what offers the second entry.

Entry

• Traders monitor for a pronounced impulse move away from a supply or demand zone, indicating strong market rejection of these levels.
• A subsequent pullback or correction phase is observed, ideally filling the imbalance left by the initial impulse. This correction signals the market’s natural attempt to retest the zone before a potential markup or markdown begins.
• A stop order might be set at the low (for bearish setups) or high (for bullish setups) that initiated the correction. This positioning aims to capture the breakout moment that confirms the market’s commitment to the new direction.

Stop Loss

• The stop loss might be placed beyond the correction. This placement is strategic, potentially minimising loss if the anticipated breakout does not materialise and the correction reverses direction.

Take Profit

• The take-profit point might be chosen within a suitable opposing zone, considering the optimal risk/reward ratio or strong support/resistance levels.

Key Takeaways

Order flow trading in forex and CFDs provides a deeper understanding of market behaviour by revealing how buyers and sellers interact through executed trades, resting orders, liquidity, and volume. By combining key concepts with tools such as the order book, footprint charts, and volume profile, traders can gain valuable insight into market sentiment and potential price direction.

While no method guarantees favourable outcomes, understanding order flow may support traders’ decisions across financial markets.

To study any order flow trading strategy on live charts, you can consider opening a trading account with FXOpen and use the TickTrader platform.

FAQs

What Is Order Flow in Trading?

Order flow represents the myriad of buy and sell orders executed in the market. It acts as a snapshot of market sentiment, showing where and how traders are placing their orders, which in turn influences price movements.

How Do Traders Read an Order Flow?

Reading order flow involves analysing the data on the volume of trades, the price levels at which they are executed, and the type of orders (buy or sell). Traders often use specialised software that visualises these data points, though they can be identified on charts through the use of order blocks and imbalances.

How Do Traders Trade an Order Flow?

Trading order flow typically involves looking for signs of imbalance between buy and sell orders and trading from order blocks. Traders often enter positions based on the anticipation that price will fill these imbalances and reverse from order blocks.

Why Is Order Flow Important in Trading?

Order flow is important because it provides insights into the immediate direction of the market, revealing the underlying demand and supply dynamics, which can be important for decision-making.

What Is the Difference Between Order Flow and Volume?

While closely related, order flow technically refers to the detailed list of transactions (buy and sell), whereas volume measures the quantity of an asset traded over a period. Order flow gives insight into the specifics of market transactions, while volume indicates the level of activity.

What Is the Difference Between Order Flow and Price Action Trading?

Order flow trading focuses on the underlying transactions that drive market movements, whereas price action trading relies on analysing the price movements themselves. Price action traders study charts for patterns and trends without necessarily considering the specific buy and sell orders that cause those movements.

What Tools Are Commonly Used for Order Flow Analysis?

The most common order flow analysis tools are footprint charts, depth of market, cumulative delta and the volume profile. Footprint charts show bid and ask volume per bar, DOM lists resting orders, cumulative delta tracks net buying against selling, and volume profile maps volume across price levels.

Can Order Flow Be Used in Forex Trading?

Yes, but with limits. Order flow trading in forex cannot draw on a full central order book, because forex trading is decentralised and each broker sees order flows of a particular broker. Traders instead read liquidity, supply and demand zones, and footprint or delta data from correlated futures as a proxy.

What Is a Cumulative Delta in Trading?

Cumulative delta is the running total of delta, where delta is ask volume minus bid volume in each bar. It shows whether net buying or selling is building over time. When price rises but cumulative delta falls, the move may lack support, a divergence traders watch for.

This article represents the opinion of the Companies operating under the FXOpen brand only. It is not to be construed as an offer, solicitation, or recommendation with respect to products and services provided by the Companies operating under the FXOpen brand, nor is it to be considered financial advice.

With only about 20% of the $10.6 billion in open interest sitting in-the-money (ITM) and the remaining 80% out-of-the-money (OTM), the market has a strong imbalance that could fuel sharp price swings as participants scramble to adjust their positions.

The story doesn’t end there.

Max pain and put-call ratio

Another factor pointing to potential volatility is the max pain price for the June 26 expiry, which currently sits at $74,000, about 14% above bitcoin’s current spot price near $65,000.

Max pain is the price level at which the largest number of options contracts would expire completely worthless. The theory suggests that as expiry approaches, the underlying asset (in this case bitcoin) tends to gravitate toward that max pain level, as market makers and traders adjust their positions.

While this “max pain” effect is widely watched in traditional markets, its reliability in crypto is often debated. Still, if the theory holds, bitcoin could see a strong bounce toward $74,000 in the coming days.

Meanwhile, the put-to-call ratio stands at 0.87, reflecting 87,156 call contracts versus 76,241 put contracts across more than $10.6 billion in notional open interest. Although call options still slightly outnumber puts, the relatively balanced positioning highlights growing uncertainty among traders.

Open interest is heavily concentrated around two key strikes. The $60,000 put holds roughly $450 million in exposure, making it an important support level, which bitcoin tested at the start of June. Meanwhile, the $80,000 call, with about $406 million in open interest, remains a significant upside hurdle.

The day’s main event is Fed Chair Kevin Warsh’s first interest-rate decision. No change in rates is expected, which means markets will be scanning the policy statement, economic projections and the post-meeting press conference for cues.

Here is what could elicit a risk-on, positive reaction from bitcoin BTC$64,644.26

The dot plot: This is a graphical representation of where individual Fed members see interest rates heading. Fed funds futures currently price in an 80% chance of a 25 basis-point increase by December. That’s the reference point for reading the plot: If it shows fewer than 80% of members projecting a hike by December, the BTC price could react positively.

Warsh’s take on rates and inflation: Will the Trump nominee break from market expectations and strike a dovish tone, citing recent oil prices and AI-driven disinflation to lay the groundwork for the rate cuts the administration wants? Or will he fall in line with current market pricing? In the former case, BTC could once again react positively.

Key Takeaways

• Australia’s High Court delivers unanimous verdict requiring licence for Block Earner’s product

• ASIC secures significant victory in cryptocurrency product regulation battle

• Full Federal Court to reconsider penalty determinations following High Court ruling

• Judges confirm crypto yield offering satisfied financial product criteria

• Company pivots business model to Bitcoin-collateralized mortgage products

In a landmark decision, Australia’s highest judicial authority has sided with the financial regulator in a critical cryptocurrency licensing battle against Block Earner. The court determined that the company’s discontinued fixed-yield digital currency product required proper financial services authorization. The matter of penalties will now be reconsidered by the Full Federal Court.

Supreme judicial body reverses lower court decision

The seven justices delivered a unanimous verdict that overturned a previous Full Federal Court judgment favorable to Block Earner. The company, managed by Web3 Ventures Pty Ltd, previously provided the Earner yield service. ASIC maintained that the offering was subject to established financial product regulations.

The highest court determined that Earner functioned as an investment facility under Australian law. Additionally, judges concluded the product qualified as a derivative instrument. The judgment noted that yields fluctuated based on digital currency valuations and foreign exchange variations.

This determination bolstered ASIC’s argument that Block Earner required proper Australian financial services authorization. The watchdog emphasized that operating without appropriate licensing deprived customers of essential safeguards under financial services legislation. The penalty phase now proceeds to the Full Federal Court for fresh consideration.

Legal proceedings clarify Australian cryptocurrency framework

ASIC initiated civil penalty action against Block Earner during November 2022. The enforcement targeted the Earner service due to the company marketing it without necessary authorization. Block Earner discontinued the offering that same month.

The Federal Court determined in February 2024 that Block Earner operated an unlicensed managed investment structure. Nevertheless, the court subsequently granted the firm relief from monetary sanctions in June 2024. ASIC contested that relief decision, while Block Earner submitted its counter-appeal during July 2024.

The Full Federal Court granted Block Earner’s counter-appeal in April 2025. It simultaneously rejected ASIC’s penalty appeal at that juncture. The High Court has now overturned those findings and reinstated the regulator’s pursuit of penalties.

Company transitions to cryptocurrency-collateralized financing

Block Earner has subsequently pivoted away from fixed-return cryptocurrency offerings. The firm obtained an Australian Credit Licence during May 2026. It subsequently unveiled intentions to launch cryptocurrency-backed mortgage solutions.

The planned service would enable borrowers to pledge Bitcoin as security for residential financing. This structure would permit customers to obtain credit while maintaining their Bitcoin positions. The licensing approval represented a significant milestone for digital asset lending services in Australia.

Nevertheless, the High Court verdict strengthens ASIC’s regulatory authority over cryptocurrency products. The ruling establishes that existing legislation applies to digital asset offerings when they satisfy financial product criteria. Consequently, cryptocurrency businesses confront increased licensing obligations under Australia’s current regulatory structure.

BitGo is expanding its custody and compliance infrastructure into Europe with a new “crypto-as-a-service” offering designed to align with the European Union’s Markets in Crypto-Assets Regulation (MiCA). The move arrives as exchanges and other regulated crypto firms prepare for a key transition point: the EU-wide requirement for authorization to continue serving customers across member states.

BitGo Europe launched the platform with the explicit aim of supporting MiCA readiness for partners that need to meet regulatory obligations for custody, trading connectivity, onboarding and wallet-related functions. According to Cointelegraph, the company is positioning its regulated setup as a way for service providers to reduce the time required to operationalize compliance measures during the licensing transition.

Key takeaways

• BitGo Europe has launched a MiCA-oriented crypto-as-a-service platform aimed at exchanges and fintech firms.
• The platform is designed to connect partners to regulated custody, trading, onboarding and wallet systems via APIs, while keeping customer-facing control with the partner.
• Compliance tooling referenced by BitGo includes programmatic KYC checks, transaction controls and settlement of supported digital assets.
• BitGo’s expansion builds on prior regulatory authorization: BaFin granted BitGo a MiCA-related license in May 2025.
• Regulatory uncertainty remains across the EU as firms seek MiCA authorizations ahead of the July 1 deadline.

BitGo Europe launches MiCA-focused crypto-as-a-service

BitGo Europe’s new platform is intended to help other crypto businesses meet MiCA requirements through a modular integration model. In its announcement shared with Cointelegraph, the company said partners can use BitGo’s infrastructure for core regulated functions instead of building all compliance and custody capabilities internally.

From an operational standpoint, the approach matters because MiCA compliance is not limited to one-off licensing paperwork. It requires firms to have ongoing systems in place that can support customer onboarding, risk controls, and transaction processing consistent with the regulation’s standards. BitGo’s service model—using application programming interfaces (APIs) to connect services—targets the practical challenge of standing up compliant workflows quickly across multiple EU jurisdictions.

BitGo stated that the service is especially relevant for companies seeking to maintain service continuity while regulatory decisions and authorization timelines evolve. In comments shared publicly by CEO Mike Belshe, he argued that regulated infrastructure can help firms keep operations moving safely and compliantly during licensing delays.

What the platform covers: custody, onboarding, controls and SEPA payments

BitGo’s MiCA-focused offering is built around connectivity to regulated custody and related functions. The company said exchanges and fintech platforms can integrate with BitGo systems for custody, trading integration, onboarding processes and wallet operations.

The service includes features intended to support compliance and operational risk management, such as programmatic KYC checks, transaction controls and settlement of supported digital assets. These capabilities are central to meeting MiCA’s expectations for regulated crypto-asset activity, where firms must demonstrate they can manage customer onboarding and transaction handling in a controlled and auditable manner.

BitGo also referenced support for euro payments through SEPA rails in eligible regions. For institutions and payment operators, the inclusion of fiat connectivity can be a significant part of operational compliance: regulated on- and off-ramp design typically intersects with AML/KYC procedures, transaction monitoring and other controls expected by regulators.

Regulatory pressure ahead of the July 1 MiCA deadline

The launch comes as EU crypto regulation transitions from fragmented national approaches toward a unified framework under MiCA. Under MiCA’s timetable, July 1 is a critical date for authorization requirements governing entities that continue offering crypto-asset services in the EU.

Recent reporting highlighted the possibility that some major exchanges may face difficulties securing authorizations in time. While BitGo did not provide details on whether its infrastructure would allow specific platforms to continue serving EU users if an authorization application is rejected, the broader compliance timing risk is evident: market participants need clarity on regulatory status, and delays can create operational and legal exposure.

Cointelegraph reported that Greek regulators may reject Binance’s MiCA license application, underscoring uncertainty surrounding the licensing pipeline for large venues. For institutions monitoring market structure, these outcomes are material not just from a business perspective, but because they affect where and how regulated service providers can legally operate across borders.

Beyond authorization decisions, MiCA-related implementation also interacts with national transition rules. BitGo pointed to markets where legacy registration regimes are being phased out as the EU-wide framework takes effect. In Lithuania, the transition period for legacy virtual asset service providers ended on Dec. 31, 2025. In Poland, implementation remains unsettled, leaving some companies navigating unclear timelines for how national approvals will map into the new EU system.

Institutional and compliance implications for crypto firms

BitGo’s move reflects a broader trend in European crypto markets: regulated infrastructure providers are increasingly central to how exchanges and fintechs build compliance capabilities. For compliance teams, outsourcing or integrating certain regulated functions can affect the internal control framework, including who is responsible for customer due diligence workflows, how transaction monitoring is performed, what audit trails exist, and how regulatory obligations are allocated across the service chain.

MiCA also creates supervisory expectations around governance, operational resilience and risk controls. While BitGo’s model is designed to enable partners to meet the MiCA standard, regulated counterparties will still need to perform their own due diligence on vendor controls and ensure that contractual and operational arrangements support ongoing compliance. This includes verifying how KYC checks are executed, how transaction controls are enforced, and how fiat-related processes interface with AML/KYC requirements.

From a historical and regulatory context, BitGo’s European expansion is not starting from zero. The company previously obtained authorization under the MiCA framework, with BaFin issuing a license in May 2025. That detail is important for institutional readers because it indicates the company is operating under an EU supervisory authorization rather than operating purely as an offshore service. In turn, this can reduce—but not eliminate—regulatory uncertainty for partners seeking integrations that align with EU oversight.

However, unresolved questions remain across the sector. Licensing decisions for major firms can change quickly, and the legal landscape will continue to evolve through regulator guidance, enforcement actions and court-related developments where applicable. Partners evaluating integrations will need to track not only the vendor’s authorization status but also the regulatory expectations for their own licensed activities.

What to watch next

BitGo Europe’s launch will likely be tested by how exchanges and fintech providers operationalize MiCA compliance under real-world timelines and regulatory outcomes across member states. Market participants and compliance teams should monitor MiCA authorization decisions, evolving national implementation details, and how regulators interpret responsibility for customer onboarding and transaction controls within multi-party infrastructure models.

BitGo says it has launched “crypto-as-a-service” in Europe, positioning the firm’s regulated custody and compliance infrastructure as a practical bridge for exchanges and fintech companies rushing to meet the EU’s Markets in Crypto-Assets Regulation (MiCA). The move comes as the July 1 MiCA authorization deadline approaches and uncertainty grows around how certain large platforms will handle licensing in individual member states.

According to a statement shared with Cointelegraph, BitGo Europe’s platform is designed to help service providers connect core functions—custody, trading support, onboarding and wallet capabilities—through APIs, rather than building an entire compliance stack from scratch. The company framed the launch as a way to keep businesses operating “safely and compliantly” during regulatory transitions, with BitGo CEO Mike Belshe arguing that regulated infrastructure can reduce downtime when licenses are delayed.

Key takeaways

• BitGo Europe launched a MiCA-oriented crypto-as-a-service platform aimed at exchanges and fintech firms that need regulated infrastructure.
• The service is presented as an API-based way to integrate regulated custody, programmatic KYC checks, transaction controls, and settlement.
• BitGo’s EU approach is tied to MiCA readiness ahead of the EU-wide July 1 authorization deadline.
• The firm says the need is acute in markets such as Poland and Lithuania, where legacy registration pathways are being phased out.
• BitGo did not clarify whether its infrastructure would allow specific exchanges to continue operating in the EU if a license application is rejected.

MiCA deadline pressure reshapes the EU custody race

MiCA sets a common authorization standard across the European Union for crypto-asset firms that wish to continue serving customers. The July 1 deadline is particularly significant for platforms that have not yet secured the required authorization to operate under the new regime.

Recent reporting highlighted the potential for uneven outcomes as regulators decide on major firms’ applications. Earlier coverage from Cointelegraph noted that Greek regulators may reject Binance’s MiCA license application, raising questions about how the largest exchange by trading volume might adjust its EU footprint if authorization does not go through.

In that environment, BitGo’s pitch is aimed at reducing friction for businesses that must comply with MiCA while continuing to offer products during the transition. While BitGo did not explicitly state how its platform would work in the event of a rejected license for a specific exchange, the emphasis on “keeping you moving” suggests an intent to support continuity where regulatory readiness is still in progress.

What BitGo Europe’s “crypto-as-a-service” includes

BitGo Europe said the product is built for integration-heavy use cases. Rather than asking partners to replace their customer-facing systems, the platform is designed to let exchanges and fintech companies plug into BitGo’s services via APIs.

BitGo’s Europe push reportedly builds on earlier groundwork: the firm obtained authorization under the relevant framework more than a year ago, and Germany’s Federal Financial Supervisory Authority (BaFin) issued the license in May 2025. With that license as a foundation, BitGo is now marketing an operational suite intended to reduce the time and cost involved in reaching MiCA-aligned operations.

Among the components BitGo describes are:

• Programmatic KYC checks that can be executed through the platform.
• Transaction controls intended to enforce rules around activity.
• Settlement support for supported digital assets.
• Euro payments via SEPA rails in eligible regions, aimed at connecting fiat on- and off-ramps to a regulated operating setup.

For exchanges and intermediaries, the practical value of this approach is that regulatory capabilities—particularly custody and compliance workflow—can be sourced from a licensed infrastructure provider. The model also potentially shifts the compliance burden away from each partner building bespoke controls, while still allowing the partner to keep direct ownership of its customer-facing products.

Regional transition gaps in Poland and Lithuania

BitGo’s statement also emphasized that MiCA transition pressures vary by country. The firm highlighted markets including Poland and Lithuania, where older national registration regimes are being phased out as the EU-wide system takes effect.

In Lithuania, BitGo points to the end of a transition period for legacy virtual asset service providers on Dec. 31, 2025. In Poland, it says implementation remains unresolved, leaving some firms in a state of uncertainty regarding which approvals they can rely on as the MiCA framework rolls forward.

This matters for operators because the compliance timeline is not uniform across jurisdictions. Even when MiCA is the overarching EU structure, companies often face a multi-layer regulatory reality—national requirements, transition rules, and regulator-by-regulator outcomes—that can affect product availability, onboarding, and the ability to process fiat rails.

BitGo CEO Mike Belshe argued that Europe is moving toward a more unified and durable regulatory framework for digital assets. In his view, MiCA readiness is not only about obtaining authorization but also about having systems that can continue functioning during licensing delays. He said the company was built for such moments and positioned BitGo Europe as a route for businesses to meet the MiCA standard while continuing to serve the market.

Open questions: continuity, licensing outcomes, and partner readiness

While BitGo’s launch is clearly aimed at helping partners operationalize MiCA compliance, important uncertainties remain. The company did not confirm whether its infrastructure would specifically allow an exchange to continue operating if a MiCA license application is ultimately rejected. Cointelegraph attempted to request clarification but did not receive a response by publication time.

For the market, the bigger takeaway is that regulated custody and compliance tooling are becoming a competitive differentiator as the EU transition tightens. Investors and industry participants will likely watch how quickly exchanges and fintech providers are able to integrate licensed infrastructure, and whether regulator decisions—such as those affecting major firms’ applications—drive further consolidation in compliance services.

With MiCA authorization decisions approaching, the next phase will hinge on how effectively exchanges and service providers can translate “license readiness” into real operational continuity—especially in countries where legacy pathways have already ended or remain unresolved.