The central bank’s directive, issued on September 7, functions as a supervisory reminder of existing European Banking Authority guidelines that took effect on December 30, 2025. By barring minimum thresholds, regulators aim to close loopholes that could allow sanctioned individuals to bypass oversight by splitting large transfers into smaller, unchecked chunks. While some traditional payment providers benefit from daily batch-screening exceptions for instant transfers, the central bank explicitly excluded crypto-asset service providers from this leniency.
Compliance officers must now ensure their automated systems verify both originator and beneficiary data before executing any transaction. This requirement exists independently of the Markets in Crypto-Assets (MiCA) licensing framework, meaning that holding a valid permit does not exempt a firm from these rigorous screening obligations. Operators are expected to audit their internal controls immediately to confirm that no automated filters are ignoring low-value transactions, a move that aligns with the broader European Union strategy to tighten financial enforcement against entities suspected of sanctions evasion.

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