KYC / KYB

CASPs are obliged entities under EU AML law and must implement a Customer Due Diligence (CDD) programme that meets the requirements of AMLD5/6. Under the GENIUS Act, US PPSIs must implement a Customer Identification Programme at bank-standard under FinCEN's CIP regulations.

KYC for crypto-asset businesses involves the same core obligations as traditional financial institutions — identity verification, beneficial ownership identification, ongoing monitoring — with additional considerations specific to crypto: self-custodied wallets cannot be verified through traditional documentary methods, and the pseudonymous nature of blockchain addresses creates attribution challenges that traditional CDD does not face.

Beneficial ownership identification is particularly important for crypto-asset businesses given the documented use of corporate structures to obscure the ultimate owners of wallets and exchange accounts. MiCAR Article 83 explicitly requires CASPs to identify and verify beneficial owners of legal entity customers using the same standards as other financial institutions.