Build the parts that make your product yours. Buy the parts every competitor also needs. Use a licensed partner for anything that moves or holds client money. That rule decides most of the stack, and the seven components below show where each piece falls.
The seven components
| Component | Who owns it either way | Usual call |
|---|---|---|
| 1. Client relationship, onboarding and pricing | You | Build. This is the product. |
| 2. Accounts and balances per currency | Whoever holds the books | Buy, unless your ledger is your edge. |
| 3. FX and liquidity across currency pairs | A liquidity provider | Buy. Each pair needs its own liquidity. |
| 4. Fiat rails in and out, per corridor | A bank or payment institution | Partner. Every corridor is another integration and another relationship. |
| 5. Custody of client assets | A licensed custodian | Partner. |
| 6. Compliance data and screening | You and your partners share it | Mixed. See below. |
| 7. Reconciliation and reporting | You | Build the controls, buy the feeds. |
Where the licence line falls
Two European rules show how fast the licence line moves.
The European Securities and Markets Authority stated on 17 April 2026 that the MiCA transitional period would end across the EU at the latest on 1 July 2026. From that date a crypto-asset service provider without authorisation had to have stopped offering services and implemented its wind-down plan. If you build custody or exchange yourself, authorisation in each jurisdiction you serve becomes your project.
The European Banking Authority said on 4 July 2024 that Regulation (EU) 2023/1113 extends the travel rule to crypto-asset service providers: information about the originator and beneficiary has to travel with the transfer. Its guidelines apply from 30 December 2024. If you build your own transfer flow, that data model is yours to implement and to audit.
Neither rule says you cannot build. Both say what building includes.
When building is the right call
- You settle in two or three currencies and one or two corridors. An issuer API plus one banking partner can cover that, and a settlement layer adds little.
- The money-handling logic is your core intellectual property, not a means to deliver something else.
- You already hold the authorisations you need in the jurisdictions you serve.
When buying is the right call
- Your clients hold or pay in many currencies. Each currency added to a self-built stack is a new account, a new rail and a new reconciliation line.
- You want to launch a corridor in weeks and test demand before committing.
- Your edge is the client relationship. Modality's line is: you own the client, we run the currencies. Balances in 36 account currencies, 630 direct pairs between them and settlement that runs 24/7 sit underneath your client relationship. See the partner page.
A test for the decision
Write down the five corridors you expect to run in year one. For each, list the rail, the partner, the currency account and who reconciles it. If the list has more than two or three distinct partners, you are building an integration business, not a product. For the partner model, see white-label payment infrastructure and direct currency pairs. The partner page describes how operators and distributors work with Modality, and engineering teams can start at the developer page.
Frequently asked questions
Can I build on a single issuer API and add currencies later?
Yes. Each added currency brings its own account, rail and reconciliation work, so the cost of the second and third currency is not small.
Does buying mean I give up the client relationship?
No. The point of a settlement layer for operators and distributors is that the client relationship stays with you.
What do I still need if I buy?
Your own onboarding, your own compliance programme for your clients, and a clear contract that says which institution provides which service.
Sources
- European Securities and Markets Authority, "Statement on the end of transitional periods under MiCA", 17 April 2026 esma.europa.eu
- European Banking Authority, press release on travel rule guidelines, 4 July 2024 eba.europa.eu
- Modality coverage sheet, July 2026 (36 account currencies, 630 direct pairs).
See the layer: .
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