2022 is about to start – what are three takeaways from 2021?

- Since its introduction in January 2020 there have been only 3 companies registering with BaFin as Crypto-Asset Custodian under the German Banking Act
- Germany has an rather elaborated crypto regulation regime and thereby outpaced EU regulation. As the current German regime relies mostly on common – demanding – standards most crypto market participants, such as (d)exchanges and DeFi-service providers, obiously (try to) avoid the German market. It is up to the year(s) coming to prove whether EU’s proposal for a Directive on Markets in Crypto Assets (MiCA) will become a game changer.
- Anti-Money-Laundering Rules will be further tightened in 2022. The EU announced a Single Rulebook on AML/CTF with an extended list of obliged entities including crypto-asset service providers.