Global Digital Finance (GDF) submitted a response to AMLA’s consultation on draft Regulatory Technical Standards under Article 28(1) of Regulation (EU) 2024/1624 relating to Customer Due Diligence (CDD).
GDF supports AMLA’s objective of harmonising CDD requirements across Member States and sectors and welcomes the draft RTS’s emphasis on proportionality, simplification, and technology neutrality.
The response highlights the importance of ensuring that AML/CFT obligations remain workable across a broad range of digital asset business models, including cryptoasset service providers (CASPs), stablecoin issuers, and infrastructure firms.
The submission recommends targeted clarifications regarding the use of privacy-preserving verification technologies, treatment of self-hosted wallets, application of blockchain analytics, and the interpretation of customer risk factors and ownership structures. GDF also encourages AMLA to ensure that technical data collection requirements remain proportionate and aligned with GDPR principles.
Additionally, the response supports the recognition of on-chain transparency and blockchain analytics as effective risk mitigation tools capable of supporting simplified due diligence measures in lower-risk digital asset contexts. Overall, GDF welcomes AMLA’s balanced and risk-based approach and encourages continued engagement with industry to ensure an effective and innovation-friendly AML/CFT framework.
Submitted:
17/04/2026