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Following the entry into force of the Markets in Crypto-assets Regulation (MiCA), on 14 July 2023 the Dutch legislator has started a consultation on the proposal for the MiCA implementation act (Uitvoeringswet verordening cryptoactiva, the Implementation Act) and it’s explanatory memorandum (memorie van toelichting). Under...

1. Introduction: Establishing the Anti-Money Laundering Authority (AMLA) has been referred to as the centrepiece of the new Anti-Money Laundering (AML) package by the EU Commission. Broadly speaking, it will promote cooperation and convergence of AML and Countering the Financing of Terrorism (CFT) practices across the...

1. Introduction: The recast of the Anti-Money Laundering Directive (AMLD) and new Anti-Money Laundering Regulation (AMLR) serve the primary purpose of the Anti-Money Laundering (AML) package to increase and facilitate cooperation between Member States in the fight against money laundering (ML) and terrorist financing (TF), while...

1. Introduction: In July 2021, the European Commission presented a new package of legislative proposals to strengthen the measures against money laundering and financing of terrorism across the European Union. This package consists of a Regulation establishing the new EU Anti-Money Laundering Authority (AMLA), an Anti-Money...

1 - Crypto-Asset Service Providers Crypto-asset service providers (CASPs) are companies that help users control, trade or store their crypto-assets. Examples include Luxembourg based Blockchain.com, a virtual cryptocurrency wallet provider responsible for facilitating 28% of global bitcoin transactions, Bitpanda, an Austrian based exchange enabling the purchase...

1. Setting the Scene According to the MiCA Article 3 definitions, asset-referenced and e-money tokens are crypto assets primarily intended as means of exchange that purport to maintain a stable value by reference to other forms of capital. However, while asset-referenced tokens may refer to baskets...