AMLA sets out five AML priorities for the EU's review of the MiCA crypto rules
The EU Anti-Money Laundering Authority (AMLA) has answered the European Commission's consultation on the Markets in Crypto-Assets (MiCA) Regulation, naming staking, DeFi and stablecoins among its concerns.
On 7 October 2026, the EU Anti-Money Laundering Authority (AMLA) published its response to the European Commission's targeted consultation on reviewing the Markets in Crypto-Assets (MiCA) Regulation. MiCA is the EU law that licenses and regulates crypto-asset issuers and service providers.
AMLA identifies areas where targeted amendments or clarifications could better address money laundering and terrorist financing risks and support consistent supervision across the EU.
AMLA lists five priorities. First, it suggests the Commission consider bringing staking, lending and borrowing within the regulatory framework because of their specific risks. Second, it suggests a clear legal definition of decentralised finance (DeFi) arrangements and common criteria for identifying who exercises effective control. Third, it encourages a consistent EU-wide approach to unauthorised stablecoins. Fourth, it suggests reviewing whether certain asset-referenced token issuers, which are not currently obliged entities under the AML/CFT framework, should fall within AML/CFT rules. Fifth, it sees scope for clearer information requirements to support cross-border supervision of service providers.
AMLA says it stands ready to support the Commission in the MiCA review. Its full response is published on the AMLA website.
Why it matters to AML professionals
Crypto activities that sit outside today's rules, such as some staking, lending and DeFi services, may be brought into scope later. AML professionals at crypto firms and at banks with crypto clients can use AMLA's list to see where EU supervisors think the gaps are. Customers active in these areas may deserve closer review now, before rules change.
Red flags in this case
- Customer funds move through DeFi protocols with no identifiable operator before reaching the customer's account
- Large flows into staking or lending products that do not match the customer's stated profile
- Use of stablecoins whose issuer is not authorised in the EU
- Rapid movement of funds between service providers in different countries with little information about the counterparty
If this landed in your queue
- Identify the DeFi, staking or lending services involved and who controls them
- Check whether any stablecoin involved comes from an authorised issuer
- Compare the activity with the customer's stated purpose and expected activity
- Document the risk assessment and escalate if the source of funds cannot be explained
Key terms
- MiCA
- The EU Markets in Crypto-Assets Regulation, which sets licensing and conduct rules for crypto-asset issuers and service providers.
- DeFi (decentralised finance)
- Financial services run through smart contracts on a blockchain, often without a clear central operator.
- Asset-referenced token
- A crypto-asset that aims to keep a stable value by referring to another value or a basket of assets.
Interview angle
Why do regulators find DeFi hard to supervise for AML purposes?
Explain that AML duties attach to a responsible person or firm, and DeFi often lacks a clear operator. Mention criteria for 'effective control' and how firms can still assess counterparty risk using blockchain analytics.
Sources
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