September 6th, Circle has responded to the European Banking Authority's (EBA) public consultation on the proposal to "extend the scope of the anti-money laundering and counter-terrorism financing guidelines to include crypto asset service providers" and raised concerns about some of the terminology used in the proposal.
Circle also believes that the term "crypto asset ecosystem service provider" is too broad, and the ambiguity of the phrase may inadvertently cover technical and ancillary service providers such as blockchain analysis and network infrastructure. The new EBA guidelines need to be technologically neutral and follow the principles established by previous EU legislation (such as the "Regulation of the Cryptocurrency Market" and "Regulation of Fund Transfers").
In addition, Circle states that self-hosted wallets are not a common indicator of high risk. Implementing fund transfer regulations will address money laundering risks when transacting with self-hosted wallets through a good risk-based approach.
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