The Federal Financial Supervisory Authority (BaFin) has published guidelines providing undertakings which intend to apply for authorisation for crypto custody business with guidance thereof, since the German Act implementing 5AMLD has included crypto custody business into the spectrum of financial services (namely into German Banking Act – KWG), requiring, therefore, an ad hoc authorisation from BaFin.

The guidlines take into account several sectors (e.g. Anti-Money Laundering/Counter Terrorist Financing, IT) whose requirements need to be fulfilled in order to obtain such authorisation, with special attention given to cyber security and risk assessments.

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