MiCA & TFR - new crypto measures in the EU

Aside from permission and registration requirements, the Markets in Crypto Assets (MiCA) Regulation requires crypto-asset issuers and crypto-asset service providers (CASPs) to establish adequate AML/CFT policies, procedures (P&P) and effective processes and controls. The amended Transfer of Funds Regulation (TFR) mandates CASPs to include information on the originators and beneficiaries of crypto-asset transfers if at least one of the CASPs participating in the transfer is based in the EU.

Obliged Entities

Custodial Wallets, Crypto Exchanges, Initial Coin Offering (ICO) Issuers, Security Token Issuers, Crypto-Trading Platforms, Crypto-Asset Advising Firms, and Crypto-Portfolio Managers.

Crypto-Assets Categories 

E-moneytokens (EMT)
Asset-referenced tokens (ART)
Utility tokens and others


The first set of MiCA regulation will take effect on June 30, 2024, while the second set will take effect on December 30, 2024, along with TFR.


Any issuer of crypto-assets and any CASP that falls under MiCA should prepare for the new changes by identifying and analysing the legal and operational impact of MiCA to remain compliant.


To comply with MiCA, AP Outsourcing Group implements all relevant internal AML/CFT policies, procedures and delivers ongoing effective systems and controls (Customer Due Diligence, Monitoring and Controls), disclosure channels with supervisory authorities and regulators, including the MLRO function for suprathreshold transaction notifications, and SAR/STR filings to FIU, record keeping and AML trainings.