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Domestic
European
Related areas
CBI FAQ on MiCAR & PSD 2 interplay: details for CASPs applying for PI authorisation to conduct EMT activities
The Central Bank of Ireland (CBI) has published an FAQ on the interplay between MiCAR and PSD2. The FAQ follows publication by the EBA in June 2025, of a 'no action letter' on this interplay.
In the FAQ, the CBI confirms that it will implement all of the recommendations contained in the EBA’s ‘no action letter’, including adopting a streamlined approach to authorisation process for crypto-asset service providers (CASPs) seeking a payment institution (PI) authorisation in order to provide the electronic money token (EMT)-related activities specified in the EBA’s ‘no action letter’.
EBA publishes final draft RTS on the prudential treatment of crypto asset exposures
On 5 August 2025, the EBA published a final report on draft regulatory technical standards (RTS) to specify the technical elements necessary for institutions to calculate and aggregate crypto asset exposures in relation to the prudential treatment of such exposures.
The RTS aim to address implementation aspects and ensure harmonisation of the capital requirements on crypto assets exposures by institutions across the EU.
ESMA publishes a list of links for complaints-handling under Article 108 of Regulation (EU) 2023/1114 Markets in Crypto-Assets Regulation (MiCA)
Under article 108(1) MiCA, competent authorities shall set up procedures that allow clients and other interested parties, including consumer associations, to submit complaints to them with regard to alleged infringement. Article 108(2) provides information on the complaints-handling procedures referred to in paragraph 1 of this Article shall be made available on the website of each competent authority.
EBA publishes new Q&As on DORA in the EBA Single Rulebook Q&As 2025
In August, the European Banking Authority (EBA) published six additional questions and answers on DORA in the Single Rulebook. The new Q&As are as follows:
EBA finds that SupTech can make AML and CTF supervision more effective
On 12 August, the EBA published a report (the report) on the use of technology tools in anti-money laundering and countering the financing of terrorism (AML/CFT) supervision (SupTech). The report takes stock of ongoing innovation efforts by competent authorities in the EU and explores how these can support the effective implementation of the new EU AML/CFT framework.
The report provides that almost half of the tools or projects which have been deployed in the AML/CFT area are already in production, an additional 30% are still under developments, with another 15% in the exploratory phase. The report outlines that National Competent Authorities (NCAs) have experienced real, tangible benefits from these tools and/or projects, including efficiencies in risk identification and improved data quality.
The EBA will continue to support the use of such technology and developments by NCAs and the Anti Money Laundering Authority (AMLA) across the EU.
FATF announce the launch of new NRA toolkit and Guidance for AML/CFT measures
The Financial Action Task Force (FATF) announced the launch of a new national risk assessment (NRA) toolkit. The NRA is aimed at enhancing the ability of countries to identify and address money laundering risks.
The focus of this new toolkit is on four currently consistently challenging areas to assess, which include:
The toolkit is designed to be adaptable to the specific needs of each country and is influenced by good practices of FATF member jurisdictions
FATF has provided updated NRA guidance, in line with recent changes to its Recommendation 1 standard and guidance on financial inclusion and anti-money laundering and counter terrorist financing measures.
OJ publishes Delegated Regulation on market abuse under MiCAR
On 20 August 2025, the Official Journal of the European Union (OJ) published Commission Delegated Regulation (EU) 2025/885 (the Delegated Regulation), which supplements the Markets in Crypto-assets Regulation (MiCAR) by providing RTS in respect of market abuse.
The RTS specify the arrangements, systems, and procedures to prevent, detect, and report market abuse, the templates to be used when market abuse is suspected, and also the procedure for coordination between competent authorities in relation to the detection and sanctioning of market abuse in cross-border market abuse situations.
The Delegated Regulation will enter into force on 9 September 2025.
EC publishes Delegated Regulation requiring a review of countries that may pose a threat to the EU financial system
On 21 August 2025, the European Commission (EC) published Delegated Regulation (EU) 2025/1184 which it had previously adopted on 8 July 2025, which introduces a review clause requiring an independent assessment of countries that may pose a threat to the EU financial system.
The EC is empowered to evaluate countries that are not publicly identified by the Financial Action Task Force (FATF) but may still jeopardize the integrity of the EU financial system. This is relevant for countries whose FATF membership has been suspended as a result of serious violations of anti-money laundering and counter-terrorism financing standards.
The Delegated Regulation will enter into force on 9 September 2025.
For more information on these topics please contact any member of A&L Goodbody's Financial Regulation Advisory team.
Date published: 30 September 2025
This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.