Does sanctions screening for crypto-assets work the same as for equities?

The legal obligation is the same, but identifying the sanctioned party can be harder: wallet addresses and pseudonymous holders don't map cleanly to the named entities on sanctions lists, so crypto funds typically need wallet-screening tools alongside name-based screening, and extra diligence on counterparty and issuer identity for tokenised securities or fund tokens.

Are crypto funds at higher sanctions risk than traditional equity funds?

Generally yes, because crypto-assets have historically been used to attempt sanctions evasion, which means regulators apply extra scrutiny to crypto-asset service providers' sanctions controls, even though the underlying legal screening obligation is the same one that applies to traditional funds.

Do crypto funds need EU sanctions screening under MiCA?

Q: Do crypto funds need EU sanctions screening under MiCA?

Crypto-asset funds and crypto-asset service providers need sanctions screening because of EU restrictive measures regulations, not because MiCA itself imposes the obligation. MiCA governs issuance, authorisation and conduct of crypto-asset services; the obligation not to deal with sanctioned persons or entities applies on top of that, the same way it applies to a fund holding equities.

Last reviewed 23 June 2026.

Yes -- but the obligation comes from EU restrictive measures law, not from MiCA itself. MiCA governs how crypto-assets are issued and how crypto-asset services are authorised and conducted; the duty not to deal with a sanctioned person or entity sits on top of that, exactly as it does for a fund holding listed equities.

Why this gets confused

MiCA is the headline new regulation crypto-asset issuers and service providers have been preparing for, so it's natural to look to it for the sanctions answer. But MiCA is a market-structure and conduct regime -- authorisation, disclosure, custody, governance. The sanctions obligation is separate: it comes from EU restrictive measures regulations (and national implementing law), and it applies regardless of what asset class the fund holds.

What's actually harder for crypto

The legal obligation is identical to an equity fund's. What's harder is identifying the sanctioned party:

Wallet addresses are pseudonymous -- a sanctions list names a person or entity, not a wallet, so linking the two needs blockchain analytics, not just a name match
Tokenised securities and fund tokens still have a real-world issuer behind them, who needs the same issuer/parent screening as a conventional security
Counterparty identity on-chain can be thinner than off-chain KYC, making ownership-based designation checks (a sanctioned person's majority-owned entity) harder to verify

The practical setup

Run name-based issuer/counterparty screening the same way a traditional fund does, and layer wallet-screening on top for on-chain exposure. Regulators apply extra scrutiny to crypto here specifically because crypto-assets have a track record of attempted sanctions evasion -- so "we do the same screening as a traditional fund" is necessary but often not sufficient on its own.

Veracore's name-based issuer/jurisdiction screening works the same way for tokenised or traditional holdings -- request a free portfolio screen to see it on your book.

EU sanctions screening for fund managers · MAR compliance for small funds

Do crypto funds need EU sanctions screening under MiCA?

Why this gets confused

What's actually harder for crypto

The practical setup

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