On September 9, the European Commission passed an authorization law that for the first time extends the existing Central Contact Point (CCP) framework, originally designed only for electronic money institutions and payment institutions, to cover Crypto Asset Service Providers (CASPs). According to publicly available materials, the extended framework empowers regulatory authorities in member states with more direct levers: as long as they operate within the country, CASPs such as crypto exchanges must designate a local contact person or liaison officer to serve as a fixed interface for regulators within the territory. This means that the previous reliance on cross-border frameworks and remote teams to address regulatory inquiries is being rewritten; compliance teams must not only obtain a unified license under MiCA but also "land a person" in every member state they enter. In the EU's planning, this is not an isolated technical fix, but an extension of an anti-money laundering regulatory line — using CCP, an existing tool, to incorporate crypto service providers into the information transmission and law enforcement coordination network originally designed for the traditional payment system, attempting to put both types of institutions on the same regulatory level regarding anti-money laundering obligations.

Extension of the CCP Framework: Equal Regulation for Crypto

Within the EU's compliance framework, the Central Contact Point was originally a set of tools serving traditional institutions. Prior to the revision, the CCP system had long only covered electronic money institutions and payment institutions, operating around anti-money laundering and compliance regulations, and was designed as a fixed information channel and interface between regulators and institutions: entities operating cross-border in member states must have a "findable person," allowing regulatory departments to continuously obtain business information, convey regulatory requirements, and promote law enforcement coordination, connecting institutions scattered across various countries into the same compliance network.

The authorization law passed on September 9 does not create a separate parallel system for crypto asset service providers but clearly includes CASPs within the existing CCP framework and connects them directly to this anti-money laundering regulatory network. After MiCA established a unified licensing framework, the European Commission chose to extend the established CCP tool, bringing crypto service providers into a familiar communication mechanism within the traditional payment system, allowing regulatory authorities in member states to have a stable and accountable communication and coordination channel domestically. Under this extended CCP framework, crypto asset service providers are regarded as having the same regulatory height as traditional electronic money and payment institutions in terms of anti-money laundering obligations.

Obligations of Local Contacts Transforming Exchanges

For exchanges operating in multiple EU countries, the requirement to "designate a local contact person or liaison officer" directly touches upon the fundamental design of their organizational structure and compliance teams. Previously, many businesses preferred to concentrate compliance hubs within a single jurisdiction and then radiate processes and standards to other markets; under the expanded CCP framework, regulatory authorities in member states have the right to require CASPs operating in their countries to establish a fixed domestic interface, which implies that the compliance function may evolve from a single headquarters model to a multi-layered structure of "regional compliance hub + member state contact person." Exchanges need to redefine who is responsible for jointly formulating anti-money laundering and trading monitoring rules, who locally interprets regulatory expectations, receives inquiries, and feeds back abnormal transaction clues, and incorporate the results of regulatory communications back into their risk control and technical systems.

The cross-border operating model will likely face a trade-off between increased localization obligations and operational complexity under this arrangement: entering each member state necessitates assessing whether the national regulatory authorities will utilize the CCP framework to require the establishment of a contact person, which brings increased management of diverse language environments, regulatory cultures, and local law enforcement rhythms. However, from a regulatory perspective, local contacts, as fixed domestic windows, are helpful for implementing the existing information transmission and law enforcement coordination mechanisms of the EU's anti-money laundering and compliance regulatory network specifically to the new entity of crypto exchanges, allowing suspicious transactions, customer due diligence, and cross-border case clues to flow more quickly both ways between regulators and platforms, thereby likely upgrading the role of local contacts in the compliance structure from "external contacts" to key nodes in the overall risk governance chain of exchanges.

Connection with MiCA and the Anti-Money Laundering Puzzle

If we consider local contact persons as new nodes in the internal compliance chain of exchanges, then this expansion of the CCP framework is about positioning this node on a larger regulatory chessboard. MiCA has already established a unified licensing and regulatory framework for crypto assets and related services across the EU, with CASPs clearly defined as core entities. Now that the same set of entities is incorporated into the existing anti-money laundering tool of CCP, it indicates that the EU no longer sees crypto services as "exceptions" existing outside the traditional financial system; instead, it incorporates them into the regular compliance track according to the logic of financial institutions.

Previously, the Central Contact Point was only applicable to electronic money institutions and payment institutions. Now, the authorization law expands its scope to crypto asset service providers, effectively "flattening" the regulatory subjects: whether traditional payments or crypto transactions, regulatory authorities in member states can require the establishment of fixed contact windows domestically, integrating the licensing management under MiCA with anti-money laundering law enforcement coordination into one network. The EU's choice to continue using the mature CCP tool rather than rebuilding an isolated system for crypto assets itself is a statement of regulatory attitude, viewing CASPs as financial service providers subject to regular compliance tools.

Simultaneous OFAC Sanctions as Global Anti-Money Laundering Tightens

Almost simultaneously with the EU passing the authorization law and extending the CCP framework to CASPs, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced sanctions against the transnational criminal organization Xinbi Guarantee, which is a Chinese platform included in the U.S. list targeting transnational financial crimes. According to general context, OFAC sanctions are among the most commonly used tools by the U.S. to respond to cross-border funding crimes, exerting pressure directly on financial transactions of institutions and individuals to cut off suspicious funding networks.

If the EU is pulling CASPs into a set of institutionalized anti-money laundering contact networks using existing CCP tools, then the U.S. uses sanctions as a targeted method, aiming at specific transnational criminal organizations. Two paths differ greatly but are highly consistent in their objectives: both are attempting to tighten compliance space for cross-border financial and crypto-related activities. It should be emphasized that there is currently no evidence indicating a direct causal relationship between OFAC's sanctions against Xinbi Guarantee and the EU's expansion of the CCP framework; they can only be viewed as concurrent contexts of tightening global anti-money laundering and financial crime enforcement environments.

Compliance Localization Era: Next Steps for EU Crypto Licenses

Returning to the EU itself, the incorporation of CASPs into anti-money laundering regulatory tools over the existing CCP framework signals a clear but still somewhat coarse directional message: crypto services are being integrated into a regulatory "whole." However, as of now, the specific numbering of the authorization law's provisions, effective timelines, and transition period arrangements have not been publicly disclosed. The qualification thresholds, boundary responsibilities, appointment procedures, and penalty mechanisms for local contact persons also lack disclosure. The number of affected CASPs and the types of services covered do not have authoritative data, and the industry can only wait for key information to emerge under the established framework outline. During this interim period, what deserves continuous tracking are how member state regulatory authorities specifically design and execute the local contact person mechanism—whether they emphasize information reporting or stronger enforcement connection—and how CASPs already operating in the EU or planning to apply for MiCA licenses adjust their internal compliance strategies, either by establishing dedicated compliance teams, authorizing local entities, or taking more cautious market entry paths. What can be determined at this stage is that the EU is pulling crypto service providers onto the unified anti-money laundering network track, but how much this step will reshape business models, cost structures, and regional layouts can only be cautiously assessed after the details are released and member states begin trial operations, combined with actual execution effects.

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