MiCA and Access to Financial Services: Disputed Client Status, AML/CFT, Sanctions and De-Risking

This ARGA Observatory report examines access to crypto-asset and related financial services where a client’s legal or compliance status is disputed. It addresses the interaction between MiCA, AML/CFT requirements, sanctions screening and providers’ risk-management decisions. Practical topics include residence and asylum documents, INTERPOL information, politically exposed person status, the origin of crypto-assets, the travel rule and blockchain analytics. Three judicial case studies and six hypothetical scenarios inform the analysis of restrictions, asset returns, complaints and data protection remedies. This publication includes the Russian and English versions.