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EBA E-mail alert 22 May, 2026

Final Q&As

Question ID: 2024_7078

Topic
Other MiCAR topics
Subject matter
Issuers of EMTs and scope of application AML requirements

To what extent should electronic money institutions (EMIs) that issue e-money tokens (EMTs) under MiCAR comply with the obligations in relation to anti-money laundering and terrorist financing under Directive 2015/849/EU (as amended, AMLD5)? More specifically, should holders of EMTs be considered as clients of the EMI within the meaning of AMLD5, so that the relevant KYC requirements apply on an ongoing basis in respect of holders of EMTs (not only at the time of issuing but also following trading on the secondary market)?

Question ID: 2024_7172

Topic
Other topics
Subject matter
Lightning Network (LN) Transactions and whether they fall within the scope of the TFR and Travel Rule Guidelines.

Do transactions on the Lightning Network fall within the scope of the TFR and Travel Rule Guidelines?

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