MiCAR’s Transitional Period Ends: AMLA’s Guidance on AML/CFT Risk

For compliance teams, the focus shifts from transition planning to evidencing a risk-based AML/CFT framework proportionate to crypto-asset products, customers and distribution channels. Firms should reassess customer due diligence, transaction monitoring, sanctions screening, travel-rule data handling and suspicious activity reporting, and ensure governance and MLRO oversight are documented. Banking, payments and investment firms with crypto exposure should also revisit counterparty and onboarding controls.

Action items: confirm MiCAR authorisation or reliance position; map AMLA guidance to existing policies; update enterprise-wide risk assessments; test monitoring and screening scenarios; close data gaps; train staff; and prepare board-level MI. The guidance does not create a new deadline, but it reinforces that supervisors will expect immediate alignment now that the transitional window has closed. Risks include remediation costs, de-risking, supervisory challenge and loss of market access for unauthorised providers.

Opportunities include greater market trust, passporting within a harmonised regime and competitive advantage for firms with mature controls.