EBA: Opinion on the EC proposal to bring virtual currencies into the scope of AMLD

EBA has welcomed EC proposal (published in July 2016) to bring virtual currency exchange platforms and custodian wallet providers within the scope of the 4th Anti-Money Laundering Directive. However, EBA states that clarifications are required and the Opinion sets out proposals addressing various issues, including the unclear transposition deadlines of the amendments; the limited suitability of PSD 2; perception of the legal status of the new entities; the need for the amendments to facilitate the cooperation between national competent authorities; the lack of specification of fit and proper tests of the new entities; and the unclear scope of the registration and licensing regime.