AML

Crypto-asset service providers are obliged entities under EU AML law. Under MiCAR, CASPs must implement an AML programme that meets the requirements of the Anti-Money Laundering Directives and the forthcoming AMLA regulation. In the US, PPSIs must implement BSA-compliant AML programmes under the GENIUS Act.

The Anti-Money Laundering Authority (AMLA) was established by Regulation (EU) 2024/1620 and begins operations in 2025. From 2027, AMLA will directly supervise a cohort of high-risk CASPs — those with cross-border operations or exposure to high-risk jurisdictions. The first cohort of 40 directly supervised entities was published in May 2026.

AMLA's supervisory methodology requires an integrated compliance management approach — not isolated tools but a coherent system connecting customer due diligence, transaction monitoring, sanctions screening, and case management. CASPs should prepare for supervisory examinations that assess the adequacy of this integration, not just the existence of individual controls.