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The EBA Guidelines on redemption plans under MiCAR

In October, we published the final Guidelines on redemption plans under the Markets in Crypto-Assets Regulation (MiCAR). The Guidelines specify, inter alia, the content of the redemption plan to be developed by issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs). The content includes the liquidation strategies of the reserve of assets, the mapping of critical activities, the content of the redemption claims, the main steps of the redemption process, and the elements that may lead the authority to trigger the plan.

date:  16/12/2024

With regard to anti-money laundering and countering the financing of terrorism (AML/CFT), the final Guidelines require that relevant checks are performed, including customer due diligence (CDD) checks on the token holders that have submitted a redemption claim. The Guidelines also require that, if the issuer is not subject to money laundering and terrorist financing (ML/TF) obligations, such activities must be performed by an intermediary which is an obliged entity under the Anti-Money Laundering Directive (AMLD). 

MiCAR entered into force on 29 June 2023 and will apply from 30 December 2024. Titles III and IV of MiCAR regarding the offering to the public and the admission to trading of ARTs and EMTs became applicable on 30 June 2024.

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