Crypto AML

Regulation (EU) 2024/1624, the Anti-Money Laundering Regulation (AMLR), applies directly in every member state from 10 July 2027, and folds crypto-asset service providers into the same list of obliged entities as banks, payment institutions and asset managers. Earlier EU anti-money-laundering directives left member states some room to interpret how far crypto rules reached; the AMLR removes that room, and its recitals state plainly that there is no AML carve-out for crypto. A CASP authorized under MiCA now plans its compliance program against the same regulation a bank reads, not a lighter crypto-specific version of it.

Transaction monitoring in a bank watches account activity for patterns that suggest money laundering: structuring below reporting thresholds, unusual counterparties, sudden changes in volume. A crypto exchange or custodian runs the same logic against blockchain data, with an added layer: it can trace the wallet's full history on the public ledger, checking whether funds passed through a mixer, a sanctioned address, or a wallet already flagged in another investigation. This is where blockchain forensics and day-to-day AML compliance overlap, since both read the same onchain data for different purposes.

The EU implemented the crypto Travel Rule through the recast Transfer of Funds Regulation, in force since 30 December 2024, which requires a CASP to collect and pass on sender and recipient data on every crypto transfer between providers, with no minimum amount at all. This goes further than the global standard of the FATF, which recommends a threshold of 1,000 euros or dollars. See Travel rule in crypto for how the data actually moves between providers and what happens with transfers to a self-hosted wallet.

The EU's new Anti-Money Laundering Authority, AMLA, has its seat in Frankfurt am Main and became operational on 1 July 2025. AMLA is working through roughly 23 technical measures it has to publish before the AMLR takes full effect, most of them due by the middle of 2026, and it will select a first group of large, cross-border financial institutions in 2027 for direct supervision from 2028, expected to include some of the largest CASPs alongside banks. For a crypto firm operating across several EU countries, this means a second supervisor to plan for, working alongside national authorities such as BaFin.

Finance Loop is the meeting place for the compliance officers and CASP teams working through the new AML rulebook, at events including When Banks Say 'No' in Frankfurt and the Bybit EU Crypto Evening at TechQuartier, where the Senior Director of Policy at Bybit spoke on compliance under MiCAR. Crypto AML sits in the Risk & Compliance track of Finance Loop, next to KYC and the travel rule.

Crypto AML covers the anti-money-laundering duties a crypto-asset service provider carries: identifying customers, monitoring transactions for suspicious patterns, screening against sanctions lists, and reporting to the national financial intelligence unit. Under the AMLR, these duties match what a bank already does.

Since MiCA introduced the CASP license, every crypto-asset service provider operating in the EU is an obliged entity under anti-money-laundering law, with the AMLR making that duty directly applicable across every member state from 2027, with no exemption for crypto specifically.

AMLA, seated in Frankfurt, coordinates AML supervision across the EU and will select a group of large, cross-border financial institutions in 2027 for direct supervision from 2028, expected to include some of the largest CASPs. National supervisors such as BaFin continue to oversee smaller and purely domestic firms.