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The full episode outline is below.

Protecting Clients: Conduct, Market Abuse and AML

RWA Leads Masterclass · Season 1: MiCA · Episode 4
Host: Fernando Verboonen

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.

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