The EU’s fifth Anti Money Laundering Directive (AMLD5) comes into force in all Member States on 10 January 2020. This latest version of the directive broadens its regulatory scope by including two types of crypto service providers (CSP): virtual-fiat exchanges and custodian wallet providers. The main driver behind this regulatory update is to decrease anonymity in crypto transactions and hence combat money laundering and the financing of terrorism. The change in the regulation confronts CSPs with three main uncertainties that need careful consideration:

  • the applicable regulatory scope and definition of CSPs
  • diverging regulatory procedures and requirements between countries
  • how to design compliant, risk-based Customer Due Diligence (CDD) procedures whilst minimising client impact.

With the deadline rapidly approaching, there is not much time left. Read this blog to learn how to start preparing your client- and internal processes before it is too late.