Industry
Banks & Financial Institutions
Digital asset products and services are increasingly being offered by traditional financial market participants. Banks and financial institutions are moving into areas such as crypto custody, trading, brokerage, exchange services, tokenised deposits, stablecoin-related services, and digital asset infrastructure.
At the same time, many institutions are modernising legacy infrastructure through distributed ledger technology, including asset tokenisation, on-chain settlement, collateral management, and new forms of market infrastructure. Because these entities are already subject to high regulatory standards, digital asset activity must be carefully embedded into existing governance, risk, compliance, operational, and prudential frameworks.
Key compliance challenges for Banks & Financial Institutions
Understanding the interaction between existing permissions and crypto-specific requirements
Assessing whether digital asset activities can be carried out under existing regulatory permissions, or whether additional authorisation, notification, approval, or crypto-specific compliance obligations apply. Even where a separate licence is not required, institutions often need to meet additional requirements linked to governance, safeguarding, disclosures, conduct, prudential treatment, and financial crime controls.
Embedding DLT within controlled operational environments
Moving from pilots and proofs of concept into controlled operational environments, while ensuring that DLT-based processes are properly governed, tested, risk-assessed, and reconciled with existing legacy systems. Institutions may need to run new digital asset infrastructure in parallel with traditional systems before broader implementation.
Upskilling staff and control functions
Ensuring that existing teams understand digital asset products, services, risks, technology, and regulatory expectations. This includes upskilling compliance, legal, risk, operations, product, audit, senior management, and customer-facing teams so they can apply their existing expertise effectively in a new sector.
Building crypto-specific AML and financial crime controls
Developing AML and financial crime frameworks that properly account for crypto-asset exposures, including the use of blockchain analytics, wallet screening, transaction monitoring, Travel Rule workflows, sanctions controls, and risk-based escalation processes.
Integrating new compliance vendors with legacy systems
Making existing onboarding, monitoring, case management, and customer risk systems work alongside specialist digital asset tools, including blockchain analytics, wallet screening, Travel Rule solutions, and custody or transaction monitoring platforms. The challenge is to create a joined-up compliance workflow that gives teams sufficient context for customer and transaction-related decisions.
Assessing prudential, capital, and safeguarding consequences
Understanding the prudential treatment of crypto-asset exposures, including potential capital requirements, risk-weighted asset treatment, liquidity considerations, safeguarding obligations, operational risk, custody risk, and the impact of digital asset activities on the institution's wider risk profile.
Recommended CARCI programmes
Examination-assessed specialist programmes for regulatory and compliance professionals.
MiCAR Specialist
EU Markets in Crypto-Assets Regulation Specialist
80h · Examination included
Travel Rule Specialist
Certified Crypto Travel Rule Specialist
12h · Examination included
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