Crypto-Asset Service Providers (CASPs) are entities that provide services related to crypto-assets on a professional basis. Under the Markets in Crypto-Assets Regulation (MiCA), CASPs are defined as legal persons or other undertakings that offer regulated crypto-asset services to third parties within the European Union.
CASPs play a central role in bridging the gap between crypto-asset projects and end-users—facilitating access, liquidity, storage, and market integrity across the digital asset lifecycle.
Under the Markets in Crypto-Assets Regulation (MiCA), Crypto-Asset Service Providers (CASPs) are classified based on the nature of the services they provide. While MiCA defines a wide range of crypto-related activities, regulatory implementation tends to group CASPs into three broad functional classes, each subject to distinct obligations in terms of capital, governance, and operational standards.
The three CASP classes
Class 1: Custody and administration of crypto-assets
This class covers entities that safeguard clients' crypto-assets or private keys on their behalf.
Key Responsibilities:
Maintain robust IT and cybersecurity frameworks
Implement asset segregation to prevent co-mingling of client and company funds
Establish procedures for recovery and business continuity
Comply with record-keeping and audit requirements
Class 2: Operation of trading platforms and exchanges
This class includes CASPs that provide an infrastructure for matching and executing crypto-asset trades between third parties.
Key Responsibilities:
Ensure transparent order book management and fair trading conditions
Prevent market abuse and apply real-time monitoring tools
Publish pre- and post-trade data
Maintain technical resilience and continuous platform availability
Class 3: Execution, reception, and transmission of crypto-asset orders
This class covers intermediaries who:
Execute orders on behalf of clients
Receive and transmit client instructions to other CASPs or platforms
Key Responsibilities:
Ensure best execution standards for clients
Avoid and manage conflicts of interest
Disclose fees, charges, and execution venues clearly
Maintain adequate record-keeping of all orders and transactions
Benefits of Obtaining a CASP Licence
Legal certainty and increased market credibility
A CASP licence under the Markets in Crypto-Assets Regulation (MiCA) provides firms with clear legal standing to operate across the EU. This regulatory clarity reduces the risk of enforcement action, enhances operational stability, and demonstrates that the business meets high compliance and governance standards.
It also boosts credibility with banks, institutional partners, and regulators—removing the “grey area” perception often associated with unlicensed crypto operations.
Ability to offer regulated crypto-asset services across the EU
MiCA introduces passporting rights, allowing authorised CASPs to provide services in all EU Member States without needing additional national licences. This significantly reduces expansion costs and administrative barriers, enabling firms to scale rapidly and legally across Europe while maintaining one regulatory home base.
Enhanced trust from investors and clients
Clients, especially institutional and risk-averse investors, are more likely to engage with MiCA-compliant CASPs. Authorisation signals that the provider meets EU standards on custody, order execution, conflict management, and consumer protection. This trust translates to higher user acquisition and retention, and may open doors to new partnerships, funding, or listings.
Competitive advantages from clear compliance structures
Licensed CASPs benefit from having formal governance, risk management, and operational policies in place. This strengthens their internal resilience and reduces legal exposure.
It also provides a competitive edge in securing banking relationships, integrating with regulated platforms, and accessing capital markets - areas where unregulated actors may face limitations.
CASP Licence Application Process under MiCA
Eligibility criteria and pre-application assessment
To obtain a CASP licence under the Markets in Crypto-Assets Regulation (MiCA), applicants must be a legal entity established in the EU and meet minimum capital requirements depending on the services provided (ranging from €50,000 to €150,000). Before formally applying, firms should conduct a pre-application assessment to:
Identify which regulated services they intend to offer
Evaluate internal readiness (compliance, staffing, IT infrastructure)
Confirm suitability of key personnel (fit and proper test)
Early engagement with the competent authority is recommended to align expectations and avoid delays.
Essential documentation and preparation steps
Detailed business and operational plans
The application must include a robust business plan, outlining:
Organisational structure and corporate governance
Target market, growth strategy, and financial projections
Description of services and value proposition
Key third-party service providers and infrastructure components
This section must also address the token types or crypto-assets the CASP expects to handle and any planned integrations with trading platforms or custodians.
Governance and risk management frameworks
Applicants must demonstrate they have implemented:
A clear and functional governance structure
Independent control functions (compliance, risk, internal audit)
Defined risk appetite and mitigation measures
Policies for safeguarding client assets and maintaining operational resilience
MiCA places strong emphasis on organisational soundness and risk oversight, especially for firms offering custody or trading services.
Compliance, AML/CFT policies and internal controls
CASPs must comply with EU financial crime prevention standards. The application must include:
A detailed AML/CFT policy aligned with Directive (EU) 2015/849 (AMLD)
Procedures for client due diligence, ongoing monitoring, and suspicious transaction reporting
Appointed MLRO and training program for staff
Internal control mechanisms to ensure ongoing compliance with MiCA obligations
Timeline and key stages in the application procedure
Cross-Border Provision of Crypto Asset Services
Regulatory Requirements for Cross-Border Service Provision
Under the Markets in Crypto-Assets Regulation (MiCA), once a Crypto-Asset Service Provider (CASP) is authorised in one EU Member State, it may offer its services across the entire EU without needing additional national licences. This cross-border provision is subject to passporting rules, ensuring harmonised compliance while facilitating the internal market.
To benefit from cross-border rights, the CASP must:
Be fully authorised by the competent authority of its home Member State
Offer only the crypto-asset services it is licensed to provide
Notify the regulator of its intention to provide services in other Member States
Passporting Rights Under MiCA Across EU Member States
MiCA introduces a passporting regime similar to that in traditional financial services. Once licensed, CASPs can operate across the EU under the same regulatory framework, avoiding duplication of authorisation processes in each Member State.
Key features include:
Single regulatory authorisation recognised EU-wide
Ability to provide services through freedom to provide services (FPS) or freedom of establishment (FoE)
Harmonised supervision through cooperation between national authorities and ESMA
This enhances legal certainty, facilitates scaling, and supports cross-border business models in a unified digital finance ecosystem.
Notification Processes for Cross-Border Activities
Before offering services in another Member State, the CASP must submit a cross-border notification to its home competent authority, including:
A list of targeted host jurisdictions
The crypto-asset services intended to be provided
Details of any physical presence or planned local branch (if applicable)
The home authority then informs the host Member States and ESMA. Once the notification is processed, the CASP may begin operations across borders without further approval.
Benefits and Compliance Considerations for Cross-Border Operations
Benefits:
Streamlined expansion into multiple EU markets
Lower regulatory overhead compared to obtaining multiple national licences
Stronger commercial positioning with institutional clients and partners
Enhanced branding and credibility as a MiCA-authorised provider
Compliance Considerations:
CASPs must maintain ongoing compliance with MiCA rules regardless of where services are offered
Marketing and consumer-facing materials must be clear, fair, and adapted to each host Member State’s language or cultural context
Must be ready for supervisory cooperation with local authorities and potential ESMA involvement in cross-border matters
Annual Fees and Ongoing Regulatory Obligations
Fee Type
Amount (€)
Annual Supervisory Fee (Class 1 CASP)
€10,000 + €2,000 per service + 0.05% of total transaction volume
Annual Supervisory Fee (Class 2 CASP)
€25,000 + €2,000 per service + 0.05% of total transaction volume
Annual Supervisory Fee (Class 3 CASP)
€50,000 + €2,000 per service + 0.05% of total transaction volume
Annual fees may be calculated based on several factors, including:
Type and number of crypto-asset services offered
Volume of transactions or client assets held
Operational scale, including geographical reach and employee count
Supervisory effort required by the authority
Regular reporting, auditing, and compliance duties
MiCA imposes a robust set of ongoing obligations to ensure transparency and risk mitigation. These include:
Periodic reporting on service activity, transaction volumes, and financial stability
Annual audited financial statements
Internal audit reports and compliance function assessments
Prompt notification of material changes (e.g. governance, business model, technical infrastructure)
CASPs must also maintain real-time monitoring systems for order execution, custody, and client asset protection.
Ensuring continuous regulatory adherence
To maintain their licence and reputation, CASPs must:
Conduct regular internal compliance reviews
Keep policies and procedures up to date with regulatory changes
Ensure all staff, especially those in control functions, receive ongoing training
Cooperate with inspections or information requests from the competent authority
How CSB Group Can Assist Your CASP Licence Application
At CSB Group, we offer end-to-end guidance for crypto-asset businesses seeking authorisation as Crypto-Asset Service Providers (CASPs) under the EU’s Markets in Crypto-Assets Regulation (MiCA). Our multidisciplinary team ensures your application is not only compliant but also strategically positioned for long-term growth across the European market.
Need our assistance with Crypto Assets, Blockchain & Fintech services in Malta?
CSB Group jest partnerem Stratus Capital Solutions od założenia firmy i strukturyzacji, która została wykonana w bardzo sprawny i profesjonalny sposób, gdyż zespół CSB przeanalizował wszystkie możliwości i przyszłe obligacje. Ze względu na doskonałą obsługę i wiedzę dostarczoną w ustrukturyzowaniu firmy, zaangażowaliśmy również CSB w zakresie usług podatkowych i księgowych oprócz funkcji sekretarza korporacyjnego. My w Stratus Capital Solutions Ltd. jesteśmy bardzo zadowoleni ze współpracy z CSB Group.
Capital Solutions Ltd.
‘I approached CSB Group in late 2022 to open a discretionary family trust. CSB have the right set up and an experienced and friendly team who helped me act on the pressing investment decisions of the trust and with opening a bank account quite smoothly. While I took the decision to establish the trust with caution, now that it is up and running, I am pleased with the result.'
UK Expat Residing in Malta
When we decided to open a company in Malta we turned to CSB. I think it was the best decision! Sacha and his team made everything seem easy and understandable regardless of the complexity of the issue. Always attentive, always available – they went out of their way to make it happen fast and hassle-free.
SIOUX MALTA LTD
A highly competent team of experienced professionals, dedicated to delivering exceptional corporate services with expertise and precision.
Luca Dalmasso
MERIDIANA Limited
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Kite Investimenti Limited of Cyclos II
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Tax Residency Client
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Tum Finance plc
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Mercury Towers
Korzystałem z usług CSB Group na Malcie, aby zarejestrować naszą firmę i nasz statek pod banderą Malty i zawsze byłem w pełni zadowolony z ich usług. Wykonują świetną robotę, są zawsze punktualni i oferują najbardziej konkurencyjne ceny w Europie! Młody i inteligentny zespół! Czasami korzystaliśmy z ich usług również przy dodatkowych zleceniach prawnych, a ostatnio korzystam z ich usług księgowych w zakresie VAT i finalizacji ksiąg. Z przyjemnością polecam usługi CSB Group.
Paolo Orlandi
Kite Investimenti Limited of Cyclos II
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Alex Rivkin
Managing Director
MLF International Limited
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Fred McCoy
NeuroTronik
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LEGOLAS INVEST LTD
In our dealings with CSB Group for over 10 years, we have found every member of the staff and leadership team to be wholly and completely knowledgeable and professional when doing business in, and from Malta.
Rhett Groom
Director
Liberation Group Holdings
We would like to thank all of you for your continuous support in the process of registering our association as a Voluntary Organisation. This is an important milestone for us which was possible thanks to your support.
Malta Male Cancer Support Association
Carousel Group partnered with CSB back in 2018 when we began this venture and they have guided and supported us through every step of the process. Despite how arduous and complex licensing a gaming business has become in recent years, we were lucky to have CSB in our corner to ensure success and build the foundations for a high-growth international business.
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Founder
Carousel Group
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EBANX
I have worked with CSB for several years, and have always found them highly professional and courteous. They are always happy to help.
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GAMING MEDIA GROUP
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Stephanie Butikofer
Tikiaora Inc Limited of Tikiaora
Die CSB Group ist seit der Strukturierung und Gründung von Stratus Capital Solutions ein Partner für das Unternehmen. Dies geschah auf sehr effiziente und professionelle Weise, wobei CSB auch das Gesamtkonzept und mögliche zukünftige Anforderungen prüfte. Nachdem wir bei der Strukturierung des Unternehmens hervorragend beraten wurden, betrauten wir CSB auch mit der Erbringung von Steuer- und Buchhaltungsdienstleistungen sowie mit den Aufgaben des Gesellschaftssekretärs. Wir sind sehr zufrieden mit der Partnerschaft mit der CSB Group.
Armand van Houten
Gründungsmitglied des Board
Stratus Capital Solutions Ltd
"I have been working with CSB for over 12 years and the words that come to my mind are trust and responsibility. CSB is an integrated part of my companies – it’s simple and safe and lets me focus on the bigger picture."
Andreas L. Borgmann
Reddo Holding Ltd
I am happy to recommend your services. Thank you Malcolm, Michela, and CSB - choosing you and your company was an absolutely correct decision. Well done!
Doublelin International Corp.
Relocating to another country is a challenging endeavor however, the support of the team at CSB Group, made a significant difference. Their guidance throughout the process instilled a sense of security and confidence, ensuring a successful outcome. Special thanks go to Michela, who displayed professionalism, and promptness, and who treated my case as if it were her own. I will always be grateful!
Family Reunification Client - English
We would like to thank Mr Roger A. Strickland Jr., Director of CSB Group, for his support throughout the application process and his team for their excellent work.
GameArt
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Retired Swiss Entrepreneur
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Annabel Bonavia
Finance Manager
Attard & Co. Industrial Ltd.
Quisiera expresar mi absoluta satisfacción por mi trato con Sacha Farrugia en el proceso de apertura de mi empresa durante las últimas semanas. Me quedé realmente impresionado con su nivel de profesionalidad y servicio al cliente. Hizo todo lo posible para asegurarse de que todas mis preguntas y curiosidades fueran atendidas y comprendidas, y su nivel de conocimiento fue excelente. No tendría ningún problema en recomendar su empresa a otras personas en el futuro y continuaré utilizando sus servicios.
Phoenix Classic Charters Limited
CSB Group has been a partner to Stratus Capital Solutions ever since the structuring and set up of the company, which was done in a very efficient and professional manner, where CSB also reviewed the bigger picture and possible future requirements. Due to the excellent service and knowledge provided in the structuring of the company, we also engaged CSB for tax and accounting services besides the corporate secretary functions. We at Stratus Capital Solutions Ltd. are very pleased with the partnership with CSB Group and their excellent employees.
Armand van Houten
Founding Member of the Board
Stratus Capital Solutions Ltd
CSB Group ha sido socio de Stratus Capital Solutions desde la estructuración y creación de la empresa, que se realizó de una manera muy eficiente y profesional, donde CSB también revisó el panorama general y los posibles requisitos futuros. Debido al excelente servicio y conocimiento brindado en la estructuración de la empresa, también contratamos a CSB para los servicios tributarios y contables, además de las funciones de secretaría corporativa. En Stratus Capital Solutions Ltd. estamos muy satisfechos con la asociación con CSB Group y sus excelentes empleados.
Armand van Houten
Socio fundador del Consejo
Stratus Capital Solutions Ltd
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Elias Berthold
Director
INCOMMUNIO Ltd
This is to express my absolute satisfaction in my dealings with Sacha Farrugia in the process of opening my company over the last few weeks. I was really blown away with their level of professionalism and customer service. They went above and beyond to ensure that all of my questions and curiosities were met and understood, and their level of knowledge was excellent. I would have no problem recommending your company to others in the future and will continue to use your services myself.
Phoenix Classic Charters Limited
"Le recomendaría vuestros servicios a cualquier empresa de juegos que planee establecer una empresa en Malta, así como solicitar una licencia de juego en Malta."
CEO
Empresa líder de casinos con distribuidor en vivo establecida en Malta
The choice of CSB Group was naturally imposed when I decided to establish my private collective investment scheme in Malta. In addition to a strong overseas reputation, it is one of the three largest and probably the most serious Maltese business advisory firms. The whole Regulated Industries and Corporate Services Team is very meticulous, attentive, and all of them would be happy to bend over backwards to advance your projects. This firm and its team are the ambassadors of one of the best onshore jurisdictions in the world.
Charles-Edouard Lambert
Founder
Magellan SICAV p.l.c.
When we decided to open a company in Malta we turned to CSB. I think it was the best decision! Sacha and his team made everything seem easy and understandable regardless of the complexity of the issue. Always attentive, always available – they went out of their way to make it happen fast and hassle-free.
SIOUX MALTA LTD
As the New Year starts I just wanted to take a moment to compliment your valuable company. I’ve been a customer of CSB Group since 2008 and I am extremely satisfied that you provide a great services for us, any issues we have had have been dealt with promptly and with a professional staff that are consistently understood our needs. They’ve always got it right first time – and on time. I simply wouldn’t recommend anyone else! Thank you once again for all your help.
Amine Tahar
Director
Ghada Holding Ltd.
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CEO
LEADING LIVE DEALER CASINO COMPANY SET UP IN MALTA
We pride ourselves in having a can-do approach conducive for our professionals to do their best work every day and to offer outstanding services.
Operations & Finance Director
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Play'n Go
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Darwin Gaming
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Barry Houghton
Primero, UK
Niedawno skorzystaliśmy z usług CSB Group w celu założenia nowej firmy. Zespół był skupiony na dbałości o szczegóły, szybko odpowiadał, a proces przebiegał niezwykle sprawnie. Nie wahalibyśmy się skorzystać z usług CSB w przypadku jakichkolwiek przyszłych zleceń.
Barry Houghton
Primero, UK
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Primero, UK
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Iforium
We have appointed CSB Trustees & Fiduciaries Limited to be the Security Trustee for a bond issued by our company; Stivala Group Finance p.l.c. The team that we worked closely with, was efficient, reliable, and knowledgeable and we couldn’t be more satisfied with the service provided. The team always made itself available even when provided with a short notice. We are glad we have engaged their services and we would definitely recommend them.
Stivala Group Finance p.l.c.
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ROYAL PANDA
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EveryMatrix Group
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An independent investment office
Ich engagierte die CSB Group in Malta, um unser Unternehmen und unser Schiff unter der maltesischen Flagge zu registrieren, und war mit ihren Diensten immer sehr zufrieden. Die Firma leistet hervorragende Arbeit, erledigt alles fristgerecht und bietet die wettbewerbsfähigsten Konditionen in Europa! Wir haben sie gelegentlich mit besonderen juristische Aufgaben betraut und seit kurzem nutze ich ihren Buchhaltungsservice zur Erstellung unserer USt-Erklärungen und Bilanzen. Ich empfehle die Dienste der CSB Group gerne weiter.
Paolo Orlandi
Kite Investimenti Limited of Cyclos II
We are impressed by CSB's continuous ambition to exceed customer’s expectations. We truly believe in long lasting partnerships, so in the past 15 years we were lucky enough to take advantage of CSB's international reach and professional services. CSB's industry experts take the administrational burden off our shoulders and let us focus on what matters - business! CSB made us both, more professional and more successful in our international commercial activities. Thank you CSB, smarter business truly starts here!
Gottfried J. Sint
Noricum Investments Ltd
"We have always received good service from CSB Group. Timing and quality have always met our expectations and everything is communicated in a professional and timely manner. Would definitely recommend to anyone considering."
FAIR PLAY BETS
Ich würde jedem Glücksspielunternehmen, das eine maltesische Gesellschaft gründen und eine Glücksspiellizenz auf Malta beantragen möchte, Ihre Dienste empfehlen.
CEO
EINES IN MALTA GEGRÜNDETEN FÜHRENDEN LIVE-DEALER-CASINO-UNTERNEHMENS
We chose Malta as our new permanent home and CSB Group to help us through the residency process. They went way beyond our expectations treating our application as if it were their own. Their service was nothing short of stellar from understanding our needs preparation of the required documentation, and follow-up phase during a period with the sharpest movement restrictions. Malta deserves a place on every investor’s radar, mostly because of the surprising efficiency permeating the place, efficiency which starts with CSB.
Christian G.
Our strength lies in our experience, passion and the human touch we apply in what we do. We have always maintained that these are the ingredients that ensure we stand out from the crowd. We believe in doing it differently. Working Smarter, not Harder.
Group CEO
We have been working with CSB for a few months now. They have been absolutely wonderful with us, guiding us every step of the way through our company setup in Malta. We value them and will continue working with them, a big thank you!
Irina Negoita
Investments Reports Limited
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Paolo Orlandi
Kite Investimenti Limited of Cyclos II
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Barry Houghton
Primero, UK
As a well-established firm with grounded knowledge and expertise, we are able to confidently understand our clients' needs and exceed their expectations.
Director
We guarantee an efficient and personalised service with an emphasis on confidentiality. Our clients' success is a reflection of our success.
Group Chairman
Back in 2015 CSB Trustees & Fiduciaries Limited has been entrusted with the project to set up a security trust for us. Their knowledge and experience within the sector made this project easier for us all. The team is meticulous, attentive and always available whenever assistance is required from our end. We would definitely recommend them for their stellar service.
Mr. Borg
Manager
Malta Properties Company Plc
We at Staern Ltd are glad that we work with CSB Group. Experienced, dedicated and supportive specialists. People you can rely on even in very complex business challenges such as VFA Licence application. People you can trust. People who can motivate and continue to go forward even in very complex business challenges. We are very glad to work with CSB Group on our VFA Service Provider Licence.
Staern Ltd
We at MIDI plc have engaged the services of CSB Group on a trusteeship basis to serve a fundamental role in our secured bond issue. Their team has always been accommodating, well-prepared and have always ensured that our requirements are met in a most timely and efficient fashion. Their services have indeed exceeded our expectations. CSB Group were identified due to their knowledge and expertise in fiduciary obligations, amongst other qualities.
MIDI PLC
Ich war mit der Zusammenarbeit mit Sacha Farrugia bei der in den letzten Wochen erfolgten Gründung meines Unternehmens absolut zufrieden. Die Professionalität und der Kundenservice der Firma waren wirklich beeindruckend. Sie stellte sicher, dass meine Neugierde und alle meine Fragen verstanden und beantwortet wurden. Ihre Mitarbeiter verfügen über ein ausgezeichnetes Fachwissen. Ich empfehle Ihre Firma gerne weiter und werde Ihre Dienste auch in Zukunft in Anspruch nehmen.
Phoenix Classic Charters Limited
"We have worked closely with CSB Group since February of 2015. They have been instrumental in helping us establish our Malta office and continue to aid us with their stellar legal and accounting services. Malta has proven to be an excellent location to establish our business, however, setting up a company with many international shareholders has been a complicated task. CSB Group has guided us along this process and we are quite satisfied with the results."
Tom Druk
CEO
AQblue Limited
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