Is AvianLabs Netherlands B.V. licensed under MiCA in the European Union?

AvianLabs Netherlands B.V. is the Dutch entity of Avian Labs, the company behind the cross-border payments app marketed as Sling Money (now rebranded as Morse). Per the company's own materials, the app is a person-to-person money app that lets users send, spend and get paid across borders using regulated stablecoins rather than operating as a traditional consumer crypto exchange. The research indicates the Dutch company is a subsidiary of Avian Labs, Inc., a Delaware (US) corporation, with the group's operating base in Amsterdam, Netherlands. Sources: Morse (Sling Money) website, AvianLabs Netherlands B.V. MiCA passport notification

On the crypto-asset side, the research describes the product as a stablecoin-based payments service settling in regulated stablecoins (specifically USDP and EURC) for peer-to-peer transfers, rather than a Bitcoin-focused spot-trading venue. Per the available summary, it does not position itself as offering spot trading, dedicated custody, savings or DCA, staking, or a card product, and it does not provide direct EUR/SEPA rails - instead relying on bank-linked transfers via regulated partners for settlement. It is described as a crypto-asset service provider (CASP), not a bank, custodian, broker or asset manager. Source: Morse (Sling Money) regulatory compliance page

On the legal point, the contracting entity is AvianLabs Netherlands B.V., supervised in the Netherlands, with the Dutch Authority for the Financial Markets (AFM) named as the national competent authority for its MiCA authorisation. Under the EU Markets in Crypto-Assets Regulation, the ESMA register records this entity as authorised for three crypto-asset services: exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, and transfer services for crypto-assets on behalf of clients. The reviewed sources also indicate the authorisation carries passporting rights to operate across the wider European Economic Area. Sources: AvianLabs Netherlands B.V. MiCA passport notification, Sling Money MiCA licence announcement

What the MiCA licence covers is therefore limited to those three exchange and transfer services. It does not, on the basis of the recorded service list, extend to custody and administration of crypto-assets on behalf of clients, operation of a trading platform, reception and transmission of orders, execution of orders, placing of crypto-assets, providing advice, or portfolio management. Anyone evaluating the entity should rely on the live ESMA and AFM registers for the current, authoritative scope of its authorisation. Source: AvianLabs Netherlands B.V. MiCA passport notification