The duty to act honestly, fairly and professionally, how client assets and complaints are handled, the market-abuse rules MiCA brings to crypto, and anti-money-laundering duties including the travel rule.
Honest, fair and professional
- Every crypto-asset service provider must act honestly, fairly and professionally, in the best interests of its clients.
- Information to clients, including marketing, must be fair, clear and not misleading, and marketing must be identifiable as such.
- Clients must be warned about the risks of transactions in crypto-assets.
Client assets, complaints and withdrawal
- Client crypto-assets and funds must be kept separate from the firm's own.
- Firms need a complaints procedure that is free of charge for clients.
- Retail buyers of 'other' crypto-assets bought directly from the offeror or a placing firm usually have a 14-day right of withdrawal.
Market abuse comes to crypto
- MiCA prohibits insider dealing, unlawful disclosure of inside information and market manipulation in crypto-assets.
- Examples: trading ahead of a listing announcement, wash trading, pump-and-dump schemes, spreading false information.
- Firms that arrange or execute transactions must detect suspicious orders and report them to the authorities.
Know your client
- Crypto-asset service providers are obliged entities under EU anti-money-laundering rules.
- That means identity checks, source-of-funds questions, sanctions screening and ongoing monitoring.
- Suspicions are reported to the financial intelligence unit, and the client is not told.
The travel rule in practice
- Regulation (EU) 2023/1113 requires originator and beneficiary information with crypto transfers between providers, with no minimum amount.
- For transfers above EUR 1,000 to or from a self-hosted wallet, the provider must check whether the client owns or controls that wallet.
- Missing or incomplete information is a reason to reject or suspend a transfer.
Key takeaways
- Fair, clear and not misleading applies to every message, marketing included.
- Insider dealing and manipulation rules now apply to crypto-assets too.
- The travel rule applies to every provider-to-provider crypto transfer, with no minimum amount.
Sources
Educational content only, not legal, tax or investment advice. Based on Regulation (EU) 2023/1114 (MiCA) and related EU texts as of September 2026. Check the official texts before relying on anything here.