ABBL response - ESMA MiCA 3 Pack - Final.pdf

Here are the key points summarized in English:

Q1: ABBL supports ESMA's analysis on personal scope of Article 92 of MiCA, but suggests clarification on transfer orders and corporate actions.

Q2: ABBL broadly supports ESMA's proposed elements for detecting and preventing market abuse, but suggests differentiation between off-chain and on-chain execution.

Q3: ABBL supports ESMA's STOR template with some reservations, including the need for clarity on account numbers.

Q5: ABBL questions the applicability of "location" to a distributed ledger, where nodes' IP addresses may be masked through VPNs.

Q6: ABBL suggests including NFTs in MAR coverage to address insider trading concerns.

Q9: ABBL recommends amending guidelines to better fit crypto-asset services and markets.

Q10: ABBL agrees with ESMA's approach on periodic statements, emphasizing consistency rather than precision.

Q11: ABBL supports ESMA's guidance for transfer services, prioritizing clients' rights and interests.

Q14: ABBL suggests clarifying the definition of "systems" to exclude decentralized ledger issues not managed by CASPs.