Rules
International standards: FATF, BIS, FSB and IMF
Behind national and EU crypto laws lies a layer of international organisations that do not make laws but do set the tone lawmakers follow. FATF, BIS, FSB and IMF each approach the topic from a different angle, from anti-money-laundering to financial stability, but their recommendations resurface in similar ways in regulation such as MiCA.
FATF: the global anti-money-laundering standard
The Financial Action Task Force sets recommendations to combat money laundering and terrorism financing, and in recent years explicitly extended these to 'virtual assets' and 'virtual asset service providers'. Its best-known contribution to the crypto world is the so-called travel rule: for transfers above a certain threshold, providers must send identifying data of sender and recipient, similar to what is already standard for traditional bank transfers.
FATF has no legislative power; countries are not obliged to adopt the recommendations literally. Yet non-compliance carries practical consequences, since FATF can place countries on black and grey lists. Such listing makes it harder for local financial institutions to maintain international banking relationships, creating a strong incentive to adopt the recommendations anyway.
In the EU, the travel rule has since been converted into binding regulation that works alongside MiCA, specifically targeting transparency for crypto-asset transfers.
- FATF recommendations are not binding but carry practical weight
- The travel rule requires identifying data on transfers
- Being placed on FATF lists complicates international banking relationships
BIS: research, bank standards and CBDCs
The Bank for International Settlements acts as a kind of knowledge and coordination centre for central banks worldwide. Through the Basel Committee on Banking Supervision, BIS has developed rules for how banks must value and hold capital against crypto-asset exposures on their balance sheets, generally with stricter capital requirements as a crypto asset is more volatile or less regulated.
Through its Innovation Hub, BIS also plays a central role in research on central bank digital currencies, CBDCs, and in cross-border pilot projects where central banks jointly test how payments between countries can become faster and cheaper using new technology. These projects are not legislation, but they do shape how central banks design their own rules on digital currency.
- Basel capital requirements for bank exposure to crypto assets
- Coordination and research for central banks worldwide
- CBDC experiments that influence national regulation
FSB and IMF: stability and macroeconomic oversight
The Financial Stability Board takes a broader view of systemic risk: how could a major shock in the crypto market spill over into the wider financial sector? The FSB publishes recommendations specifically targeting crypto assets and stablecoins, with attention to cross-border cooperation between supervisors, since crypto markets pay little heed to national borders.
The IMF approaches crypto from a macroeconomic angle: what does widespread crypto adoption mean for monetary policy, exchange rate stability and capital flows, especially in countries with weaker domestic currencies? The IMF regularly advises member states on national crypto policy and sometimes links that advice to broader financial support programmes, increasing the weight of these recommendations compared with purely technical advice.
- FSB focuses on systemic risk and cross-border supervision
- IMF looks at monetary and macroeconomic consequences of crypto
- Neither organisation has binding authority, yet both carry significant influence
How this feeds into EU regulation such as MiCA
MiCA did not emerge in a vacuum; when drafting it, EU lawmakers explicitly looked at FATF recommendations on the travel rule and at broader international discussions on stablecoins, partly driven by the FSB following earlier concerns about large-scale, globally usable coins. The attention MiCA pays to asset-referenced tokens partly stems from international concern about the impact of such coins on financial stability.
At the same time, the EU keeps charting its own course: MiCA goes further on some points than international standards strictly require, for example with a full licensing regime for providers rather than just anti-money-laundering obligations. International standards therefore form a floor and a shared language, not a ceiling for the rules a region like the EU introduces.
Frequently asked questions
Are FATF recommendations legally binding?
No, FATF has no legislative power. Countries that ignore the recommendations risk being placed on a black or grey list, which complicates international banking relationships.
What exactly is the travel rule?
The travel rule requires providers to send identifying data of sender and recipient for crypto-asset transfers above a certain threshold, similar to bank transfers.
What is the difference between BIS, FSB and IMF?
BIS focuses on research, banking supervision and CBDCs, the FSB on systemic risk and cross-border coordination, and the IMF on macroeconomic and monetary policy.
How do these organisations influence MiCA?
MiCA adopts elements such as the travel rule and attention to stablecoins, but goes further on some points than international standards strictly require.
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