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December 5, 2024Crypto Compliance Special Edition
The EU’s Markets in Crypto-Assets Regulation (MiCA) is now fully in force. Whether you’re a crypto-asset service provider, a traditional financial institution, or advising clients in this space, here’s what you need to know.
📅 Key Dates to Remember
- June 30, 2024 – Stablecoin provisions took effect
- December 30, 2024 – Full MiCA application for crypto-asset service providers (CASPs)
- July 1, 2026 – End of transitional period for existing providers
🔐 AML Requirements Under MiCA
MiCA brings crypto-asset service providers firmly within the EU’s AML framework:
Customer Due Diligence
- Full KYC required for all customers—no more anonymous transactions
- Enhanced due diligence for transactions over €1,000 from self-hosted wallets
- Ongoing monitoring of customer relationships
Travel Rule Implementation
- Transfer of Funds Regulation (TFR) applies to crypto transfers
- Originator and beneficiary information must travel with transactions
- Screening required before executing transfers
Suspicious Activity Reporting
- CASPs must file SARs with national FIUs
- Blockchain analytics becoming mandatory for larger providers
- Staff training requirements on crypto-specific red flags
🚨 Common Compliance Gaps
Based on our client work, these are the most frequent issues we see:
- Wallet screening deficiencies – not checking for sanctioned or high-risk addresses
- Transaction monitoring blind spots – missing layering through DeFi protocols
- Incomplete AML policies – not covering crypto-specific typologies
- Travel Rule technology gaps – no solution for information exchange
✅ Your 30-Day Action Plan
| Week | Action Item |
|---|---|
| Week 1 | Complete AML policy gap analysis for MiCA requirements |
| Week 2 | Implement or upgrade blockchain analytics tools |
| Week 3 | Train staff on new procedures and red flags |
| Week 4 | Test Travel Rule information exchange capabilities |
Navigating MiCA compliance? Our team specializes in crypto-asset AML programs. Explore our services.