Crypto AML
Anti-money-laundering law used to treat crypto as a special case with lighter rules attached. That gap is closing fast: the EU's new single rulebook puts crypto-asset service providers under the same customer checks, transaction monitoring and reporting duties as banks, with no carve-out left for digital assets. A CASP's compliance program now has to do everything a bank's does, adapted to a blockchain instead of a ledger of account numbers.
The AMLR closes the crypto exemption
Regulation (EU) 2024/1624, the Anti-Money Laundering Regulation (AMLR), applies directly in every member state from July 10, 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.
What crypto transaction monitoring has to catch
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 Travel Rule: no minimum amount in the EU
The EU implemented the crypto Travel Rule through the recast Transfer of Funds Regulation, in force since December 30, 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 FATF's own global standard, 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.
AMLA in Frankfurt: a new supervisor for the largest firms
The EU's new Anti-Money Laundering Authority, AMLA, has its seat in Frankfurt am Main and became operational on July 1, 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 from 2027 it will begin direct supervision of a first group of large, cross-border financial institutions, 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.
Upcoming events on compliance and digital assets
Finance Loop and crypto AML
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 Bybit's Senior Director of Policy spoke on compliance under MiCAR. Crypto AML sits in Finance Loop's Risk & Compliance track, next to KYC and the travel rule.
Risk & Compliance
Investment & Digital Assets
What is crypto AML?
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.
Do crypto exchanges have to follow AML rules in the EU?
Yes. 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.
What does AMLA do for crypto firms?
AMLA, seated in Frankfurt, coordinates AML supervision across the EU and will directly supervise a group of large, cross-border financial institutions from 2027, expected to include some of the largest CASPs. National supervisors such as BaFin continue to oversee smaller and purely domestic firms.
Crypto AML and Finance Loop
Crypto AML is a recurring topic at Finance Loop's compliance events in Frankfurt, including When Banks Say 'No' and the Bybit EU Crypto Evening, where MiCAR compliance and anti-money laundering law came up directly. The topic sits in Finance Loop's Risk & Compliance track, alongside KYC and the travel rule.
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