crypto-asset service providers

  • BaFin AMLA Guidelines: Overview Table Replaces Adoption Circulars

    On 1 October 2026 the German Federal Financial Supervisory Authority (BaFin) started publishing a tabular overview of which guidelines issued by the European Supervisory Authorities (ESAs) and by the EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) it has adopted into its administrative practice, and which it has not. In the…

  • FINMA Belarus Sanctions: The 19 September Crypto and Credit Bans

    On 18 September 2026 the Federal Council amended the Ordinance of 16 March 2022 on Measures against Belarus (SR 946.231.116.9), and the changes took effect in Switzerland on 19 September. FINMA flagged the change in a notice on 25 September. The FINMA Belarus sanctions notice points to a financial package modelled on the Russia regime:…

  • CARF Reporting in Luxembourg: DAC8 Crypto Filing by 30 June

    CARF reporting in Luxembourg starts with the data a crypto-asset platform is already generating in 2026. The Law of 27 March 2026 (Mémorial A No. 144), which transposes Directive (EU) 2023/2226 (DAC8) and brings the OECD Crypto-Asset Reporting Framework into Luxembourg tax law, makes the calendar year 2026 the first reporting period. Reporting crypto-asset service…

  • MiCA CASP Wind-Down: What Unauthorised Providers Must Do as the Transitional Period Ends on 1 July 2026

    MiCA CASP wind-down becomes the immediate operating question where a crypto-asset service provider reaches the end of its applicable transitional period, and in all cases 1 July 2026, without a MiCA authorisation. The provider cannot keep trading. It cannot onboard. In most cases it cannot even continue holding client crypto-assets except for the short window…

  • AMLA Direct Supervision: Which Obliged Entities the CSSF Will Identify

    The most expensive scoping mistake a Luxembourg compliance team can make right now is assuming someone else will flag it for AMLA direct supervision. The Authority for Anti-Money Laundering and Countering the Financing of Terrorism picks its first set of directly supervised firms in 2027, and the data that feeds that decision is being collected…