Sanctuary Research

MiCA has been "coming" for so long that some teams treated it as weather. It is no longer weather. ESMA's April 2026 statement puts the remaining transition periods on a clear track: by July 1, 2026, the old grey-zone footing is over.
That does not mean every questionable service disappears on July 2. It means counterparties, banks, issuers, and licensed CASPs get a cleaner reason to ask hard questions: who are you, where are you licensed, and what happens when we screen your flow?
The EBA Travel Rule guidelines bring originator and beneficiary data into crypto transfers. In practice, that makes "we only touch wallets" a weaker excuse. Once flow crosses a regulated service, missing identity context and weak screening become operational defects.
For smaller desks, the painful part is not writing a policy. It is proving daily execution: checks before acceptance, escalation records, watchlists, and evidence that decisions were not made after the fact.
Expect more rejected deposits, more frozen payouts, more documentation requests, and more platform bans for counterparties who cannot explain their AML process. Some teams will try to move volume into offshore wrappers or informal OTC chains. That may buy time, but it increases the taint profile.
The market signal is simple: if your flow cannot survive a wallet check, the licensing deadline is not your only problem.
ESMA, statement on the end of MiCA transition periods: https://www.esma.europa.eu/sites/default/files/2026-04/ESMA75-113276571-1679_Statement_on_the_end_of_transitional_periods_under_MiCA.pdf
EBA, Travel Rule guidelines for crypto-asset transfers: https://www.eba.europa.eu/activities/single-rulebook/regulatory-activities/anti-money-laundering-and-countering-financing-terrorism/guidelines-information-requirements-relation-transfers-funds-and-certain-crypto-assets-transfers
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