Home » What will be the actual impact of the European Anti-Money Laundering Regulation (AMLR)?

What will be the actual impact of the European Anti-Money Laundering Regulation (AMLR)?

by Tim

The implementation of regulatory frameworks sometimes blurs the lines between investor protection and generalized surveillance. This situation applies more specifically to the AMLR (Anti-Money Laundering Regulation), which will come into force in the European Union in July 2027. This ambitious measure requires some clarification in order to assess its actual scope without falling into alarmist paranoia.

AMLR: a problematic regulatory framework?

Some people still wonder what cryptocurrencies are good for. Perhaps they can be used to maintain a certain independence from the surveillance applied to financial flows, at a time when cash is gradually disappearing, although it is important to note that Sweden—a pioneer in this field for many years—has finally backtracked on the issue.

This situation is also accentuated by the introduction of central bank digital currencies (CBDCs) and the risk of control associated with them. This development is currently underway in the European Union, with deployment expected in 2029, and a joint desire for strict control of stablecoins.

In this context, independent researcher Shanaka Anslem Perera has just sounded the alarm about a text that “treats every citizen like a criminal.” At issue are transactions such as buying a car with cash or sending more than €1,000 in Bitcoin, which could soon become suspicious.

This was an opportunity for Shanaka Anslem Perera to point out that the legitimate fight against money laundering—estimated at $500 billion annually—has a perverse effect in the form of possible mass surveillance of the European Union population.

Cash payments: no change for the French

In practice, this regulation involves a highly controversial measure designed to limit cash payments to a maximum of €10,000.

This situation does not really affect France, as restrictions already exist in this area between individuals and professionals, with a maximum amount set at €1,000. For cash payments made directly between individuals, this limit rises to €15,000.
The aim of the AMLR is therefore to harmonize practices among European Union member states, as cash remains very popular in countries such as Germany and Austria, which are directly affected by this new restriction.

Cryptocurrencies: more targeted than generalized surveillance?

With regard to cryptocurrency transfers, the objective of this text—which is in line with the Transfer of Funds Regulation (TFR)—does not involve generalized surveillance of on-chain transactions, as was suggested on social media.

In fact, the announced tracking will “only” apply to transactions exceeding €1,000 originating from a self-custody wallet involving interaction with a regulated service provider (PSAN), such as the cryptocurrency exchange platforms Binance, Kraken, or Coinbase.

In the case of transfers between individuals (directly from wallet to wallet), this monitoring does not apply.

However, it is important to note that any transaction carried out with a regulated service requires the identification of both parties and the recording of transaction information.

Collateral risks of crypto data leaks

At the same time, another factor is emerging as potentially risky, with the implementation of the European DAC8 directive, which involves a broader consideration of cryptocurrencies in the field of tax obligations in order to optimize the fight against tax fraud and evasion.

This desire for transparency exposes the information collected on taxpayers’ digital assets to major risks due to its centralization. Indeed, this could make it possible to identify prime targets for cybercriminals or organized networks.

One need only look at how a tax agent has recently been suspected of passing confidential tax data to criminal groups to understand the potential scale of this security breach, particularly in a context of kidnappings and abductions of crypto players for ransom.

Tax agent suspected of informing organized crime

In an ecosystem where the principle of self-custody is based on individual responsibility, the protection of personal data is now as crucial as that of private keys.

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