Obligation map · crypto settled value
European Union → South Africa
What obliges a firm moving value on this corridor, with the instrument and the source against each. Free, and permanently at this address. The framework is currently in flux and next reviewed .
The obligation stack
EU leg
Hold MiCA authorisation as a crypto-asset service provider to provide services in the EU
Regulation (EU) 2023/1114 (MiCA)
Binds — Any entity providing crypto-asset services to EU clients
Evidence that satisfies it — MiCA authorisation from the home NCA; Passporting notification where services cross member states
in force · Consistent across independent analysis; primary source not yet read · Compliance vendor analysis · reviewed
Collect and transmit full originator and beneficiary data on every crypto-asset transfer, with no de minimis threshold, including transfers to third-country counterparties
Regulation (EU) 2023/1113 (Transfer of Funds Regulation)
Binds — Authorised CASPs transferring crypto assets
Evidence that satisfies it — Travel rule messaging capability; Counterparty CASP due diligence; Records of transmitted originator and beneficiary data
in force · Consistent across independent analysis; primary source not yet read · Compliance vendor analysis · reviewed
ZA leg
Register as an accountable institution with the Financial Intelligence Centre and discharge customer due diligence, travel rule, reporting and record-keeping duties
Financial Intelligence Centre Act 38 of 2001, Schedule 1 as amended
Binds — Crypto asset service providers as accountable institutions
Evidence that satisfies it — FIC registration confirmation; Risk Management and Compliance Programme; Travel rule implementation evidence
in force · Consistent across independent analysis; primary source not yet read · Compliance vendor analysis · reviewed
Hold an FSP licence with crypto asset services authorisation to provide crypto asset services in South Africa
Financial Advisory and Intermediary Services Act 37 of 2002, as applied by the FSCA declaration of crypto assets as a financial product (2022); Category I sub-category 1.28
Binds — Crypto asset service providers operating in or into South Africa
Evidence that satisfies it — FSP licence certificate showing sub-category 1.28; Key individual approval; Fit and proper evidence
in force · Consistent across independent analysis; primary source not yet read · Law firm analysis · reviewed
What changed
The changes themselves are public — a gazette was published, a deadline passed. What each one means for this corridor, and what a firm on it has to do differently, is the log. That is the part you subscribe to.
· EU · high severity
MiCA transitional period ends. A CASP without authorisation may no longer operate in the EU
Legal analysis · assessment in the log
· ZA · medium severity
FSCA reports 533 CASP licence applications received, 310 approved, 17 declined
Law firm analysis · assessment in the log
Claims checked on this corridor
The EU-ZA obligation stack is evidenced by primary sources
unsupported
Every obligation on this corridor is currently evidenced by tier 3 material: law firm and compliance-vendor analysis. The instruments are named and the analysis is consistent across independent sources, but no obligation has been read against the gazette, the regulation text or the regulator register. Recorded as owed, not as done.
A crypto-settled transfer from the EU into South Africa can lawfully be made between any two counterparties
contradicted
It cannot. The EU leg requires an authorised CASP and full travel rule data on a third-country transfer; the South African leg requires both an FSP licence carrying crypto authorisation and FIC accountable institution registration. The corridor is licensed-to-licensed, and the number of parties on the South African side who satisfy both is smaller than the number who present as operating.
EU travel rule obligations stop at the EU border
contradicted
They do not. Reported enforcement includes administrative fines by a national competent authority for systematic travel rule failures on transfers to non-EU counterparties. A South African beneficiary does not remove the originating CASP obligation.
Next dates to watch
Listed because a date you do not know about is the expensive kind. Subscribers are alerted ahead of each one, with what it changes for this corridor.
· fixed
Close of comment, draft Crypto Asset Manual
What is free and what is not
Everything above is free and always will be — no login, no email, no form. Copy it, cite it, print it. The map is not the product.
The product is that it stays correct. Fourteen regulator sources are watched so that when one of these obligations moves, subscribers are told what moved, what it means for this corridor, and what to do differently — and can later export a dated, sourced record proving they were told. A map you copied today is a photograph. It starts rotting immediately, and you will not know when it does.