MONEYVAL Report on Crypto-Assets: Regulatory Implications for VASPs and CASPs in Poland

In December 2025, the Council of Europe’s Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) published an updated typologies report addressing ML/TF risks in the crypto-asset sector. The document places particular emphasis on threats related to the circumvention of international sanctions.

For Fintech entities, including Virtual Asset Service Providers (VASPs) and Crypto-Asset Service Providers (CASPs), the report serves as a vital roadmap regarding upcoming supervisory priorities that will also be relevant for the Polish market.

Tightening Regulation of the Crypto-Asset Market – Licensing and Supervision of VASPs and CASPs

One of the key trends identified in the report is the continued strengthening of regulatory oversight in the sector. Currently, as many as 81% of MONEYVAL jurisdictions require VASPs to obtain a licence or registration. More than 90% of states have already designated competent supervisory authorities responsible for supervising this market.

At the same time, the report notes that the detection rate of entities operating without the required authorisations remains low. Many jurisdictions still struggle with a lack of structured data on cross-border capital flows in crypto-assets, which makes effective market supervision significantly more difficult.

Travel Rule and Regulation (EU) 2023/1113 (TFR) – Implementation Status and Implications for the Crypto-Asset Market

A key risk area remains the slow operationalisation of the so-called Travel Rule. While it originates from the FATF standards, within the European legal framework the key legislative instrument is Regulation (EU) 2023/1113 (TFR), which is still in the implementation phase in many MONEYVAL member states.

According to the report, only 46% of the surveyed jurisdictions have fully implemented transfer transparency requirements applicable to the crypto-asset sector.

International Sanctions and the Circumvention of Sanctions through Crypto-Assets

The report also highlights the risk of crypto-assets being used to circumvent targeted financial sanctions. Although most jurisdictions impose sanctions compliance obligations on service providers, mechanisms for detecting breaches are often insufficient.

Emerging criminal typologies include the use of crypto-assets by state-sanctioned entities as well as proliferation financing.

New Money Laundering Typologies in the Crypto-Asset Sector

MONEYVAL points to the growing use of virtual assets in the online gambling sector and in investment fraud schemes. Criminals are increasingly relying on so-called money mules and anonymity-enhancing tools, such as cryptocurrency mixers.

In response to these threats, supervisory authorities are increasingly deploying advanced analytical tools (blockchain analytics tools) and promoting Public-Private Partnerships (PPPs).

While these initiatives are gaining traction, currently only 40% of jurisdictions have active cooperation programmes with the private sector involving crypto-asset market providers.

Do You Need Support with AML Regulation in the Crypto Market?

If you operate in the crypto-asset sector and would like to assess whether your internal processes comply with current AML requirements and EU regulations, please contact our team.