On 11 August 2016, the EBA wrote an Opinion on the application of 4AMLD to VC exchanges and wallets.
The EBA mentions that VC exchanges and wallets operating in multiple countries in the EU “may […] be required to be registered or licensed in each Member State in which they intend to provide VC-related services“.
This would be akin to the state-by-state registration process that VC exchanges have to do in the United States.
This is due to the fact that there are no passporting rights granted under the 4th Anti-Money Laundering Directive – understandable, as the regulations are not designed to facilitate the movement of goods, services or capital but are simply motivated by the public policy imperative of protecting the European Union from terrorism and crime.
Read more here.