Bitkom welcomes the creation of a European framework for reaching goals linked to Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) through the Transfer of Funds Regulation (TFR). For Bitkom, concerns remain surrounding the potentially disproportionate measures with regard to Self-Custody Wallets, which could put EU’s potential for innovating financial services at risk. Bitkom is also concerned about the proposals regarding the collection, recording, verification, and reporting requirements in connection with these wallets. Moreover, we call for utilizing the benefits of Distributed Ledger Technology (DLT) based systems and want to highlight the importance of a cautious approach when it comes to creating obligations for CASPs to verify the adequacy of data protection rules in non-EU jurisdictions.
