Surveillance

An unresolved EBA Single Rulebook Q&A asks whether MiCA e-money token issuers must treat every holder as a client for AML purposes on an ongoing basis, including after secondary-market transfers. The answer, now pending with the European Commission, will decide whether MiCA-compliant stablecoins remain open, transferable digital money or become permissioned, surveillance-heavy e-money systems. The question applies to euro tokens such as EURC and to dollar tokens like USDC issued under MiCA, and it helps explain why Tether has stayed out. Europe's competitiveness and privacy both turn on whether obligations attach to real control points or to issuers alone.