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. In July 2027, the European Anti-Money Laundering Authority will formally select up to 40 of the EU's highest-risk cross-border obliged entities for direct supervision, which begins in January 2028.

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.