CARCI
Enterprise & Industries

Industry

Payment Institutions

Payment institutions are increasingly being pulled into the digital asset ecosystem as stablecoins, tokenised money, on-chain settlement, and crypto payment services become more closely connected with mainstream payments infrastructure. For payment firms, the opportunity is not only to support digital asset businesses, but also to modernise payment flows, settlement models, cross-border transfers, merchant acquiring, and customer-facing payment products.

Payment Institutions

At the same time, payment institutions operate in a highly regulated environment where customer protection, safeguarding, operational resilience, financial crime controls, and payment system integrity are central. This means that digital asset-related activity must be carefully assessed against existing payment services obligations, crypto-specific requirements, stablecoin rules, and financial crime compliance expectations.

Key compliance challenges for Payment Institutions

Assessing whether a stablecoin can be used in regulated payment flows

Determining whether a stablecoin is legally permitted, appropriately regulated, and operationally suitable for use in payment services. This includes assessing the status of the issuer, redemption rights, reserve arrangements, token classification, jurisdictional restrictions, and whether the stablecoin can be used for customer payments, merchant settlement, or internal treasury flows.

Understanding the interaction between payments regulation and crypto-specific rules

Mapping where existing payment services, e-money, safeguarding, consumer protection, and conduct obligations intersect with crypto-specific requirements. Payment institutions may need to understand whether a product remains a payment service, becomes a crypto-asset service, or creates overlapping obligations.

Building fraud prevention controls for digital asset payment models

Adapting existing anti-fraud systems to digital asset payment flows, including wallet-based payments, stablecoin transfers, crypto-linked cards, merchant payments, and cross-border transactions. This may require stronger monitoring for scams, authorised push payment fraud, mule activity, account takeover, social engineering, unusual wallet behaviour, and high-risk beneficiary patterns.

Embedding Travel Rule compliance into payment workflows

Assessing how Travel Rule obligations apply to crypto-asset transfers and integrating originator and beneficiary information into payment workflows. This includes coordinating data collection, counterparty checks, message exchange, sanctions screening, and escalation handling across fiat, stablecoin, and crypto payment rails.

Integrating digital asset monitoring with existing payment systems

Connecting blockchain analytics, wallet screening, Travel Rule tools, fraud monitoring, sanctions screening, customer onboarding, transaction monitoring, and case management systems into one coherent compliance workflow. The challenge is to give compliance teams a full view of the customer, the wallet, the transaction, and the payment purpose.

Managing operational and third-party dependency risk

Assessing reliance on stablecoin issuers, wallet providers, custody partners, exchanges, blockchain networks, payment processors, and technical vendors. Payment institutions need to understand how outages, failed transactions, smart contract issues, liquidity constraints, or partner failures could affect payment execution and customer outcomes.

Recommended CARCI programmes

Examination-assessed specialist programmes for regulatory and compliance professionals.

MiCAR Specialist

EU Markets in Crypto-Assets Regulation Specialist

80h · Examination included

View programme

Travel Rule Specialist

Certified Crypto Travel Rule Specialist

12h · Examination included

View programme

Train your team in crypto-asset compliance

Team and enterprise access is available for organisations.

Team & enterprise plans