When transaction monitoring rules are stale: what to do first
The first step is to freeze new onboarding under the stale ruleset, document the date the monitoring parameters were last reviewed, and route the file to the person who signed off on the current thresholds. Everything else — recalibration, retrospective look-back, supervisor notification — follows only after that record exists.
Where the obligation sits
Obliged entities providing crypto-asset services carry monitoring duties under Regulation (EU) 2023/1114 (MiCA), in force from 30 December 2024. Wait — external link not allowed. Let me not link source.