In conclusion, the current Croatian AML act does not regulate crypto-assets. However, the proposed AML act intends to regulate crypto-assets and require legal and natural persons providing exchange services for virtual and fiduciary currencies or providing wallet custodial service to comply with the proposed AML act. In addition, it seems that under the proposed AML act, all transactions undertaken with crypto-assets which fall under the foregoing definitions (virtual currencies, investment and security tokens) will be considered as assets and therefore the entities dealing with crypto-asset transaction must also comply with the proposed AML provisions.
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