CryptoReflexions#19 - Coinbase Sanctioned in Ireland for Non-Compliance with Anti-Money Laundering Law

Hello everyone,

Today, a reflection on the sanction imposed on Coinbase by the Central Bank of Ireland — and what it reveals about the growing regulatory requirements in Europe.

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The Sanction

In November 2025, the Central Bank of Ireland imposed a fine of 21.5 million euros on Coinbase Europe for serious shortcomings in its anti-money laundering (AML) system. This event is of particular significance as MiCA comes into full effect in Europe.

The Identified Shortcomings

Three programming errors compromised the functioning of five monitoring scenarios out of twenty-one. These failures prevented the complete detection of certain transactions for several months in 2021-2022.

Following this discovery, the company reanalyzed all affected transactions and filed approximately 2,700 suspicious transaction reports (STRs).

What This Means for the Industry

This sanction establishes several guiding principles:

Technological vigilance: Software errors are no longer an acceptable excuse. Platforms must regularly document their monitoring tests and immediately report any malfunction affecting detection.

Proactive approach: Regulators expect internal self-correction rather than a reaction following an inspection. In Belgium, the FSMA has been strengthening its controls since 2024 following this same logic.

Uniform compliance: Every crypto-asset service provider operating in the EU must comply with the same standards, regardless of its state of establishment.

Consequences for Users

These reinforced requirements concretely translate into more rigorous KYC checks, increased requests for proof of origin of funds, and strict application of the travel rule for transfers.

It is strongly advised to maintain clear documentation on the provenance of your digital assets.

Conclusion

Authorities now demand impeccable and responsive controls. Compliance is no longer a box-ticking exercise — it is an operational infrastructure that must function in real time, and whose technical failures engage the platform’s liability.

To go further: cryptomonnaie.be — The cryptocurrency blog in Belgium | Newsletter CryptoBelgique — Stay informed about news and updates

Florian ERNOTTE Lawyer 👉more infos about what i do