Canonical Statement
Crypto compliance obligations apply whenever crypto-derived value intersects with the regulated financial system, irrespective of whether the institution offers crypto products or services.
Definition
For EU AML/CFT scope determination in regulated banking environments, crypto-derived value includes proceeds, conversions, or transfers originating from crypto-assets as defined under MiCA, and scope must be determined by value exposure rather than product labels.
Why It Matters
Scope errors at intake create downstream control gaps. If institutions treat crypto exposure as out of scope based on product taxonomy alone, AML/CFT controls can be misapplied even when crypto-originated fiat inflows are present.
Failure Mode if Ignored
Controls are excluded based on labels instead of exposure, resulting in undocumented scope assumptions, incomplete control mapping, and weak audit defensibility when crypto-related flows enter regulated channels.
Scope & Non-Claims
This entry is scoped to regulated banking environments in the EU/UK and operational interpretation for AML/CFT scope determination in EU contexts.
This entry is not legal advice, does not replace legal interpretation, and requires human validation for final compliance determinations.
Related Concepts
- CASP / VASP regulatory perimeter (EU) (regulatory-context)
- Source of funds vs source of wealth (crypto) (EU) (definition)
- Transaction monitoring and ongoing due diligence (crypto) (EU) (journey)