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+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:32:11Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:c2844101dedd027a3b7d73a8", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::4f1::4905", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "Treasury received substantial feedback\nfrom a range of stakeholders with industry-wide support for clarity on the regulatory settings for crypto\nassets. In particular, key stakeholders flagged the need to prioritise the 'token mapping' work, which\ninvolves reviewing a range of crypto assets to identify how they fit within the existing regulatory framework. Accordingly, to commence the reform agenda, I will prioritise the complex 'token mapping' work in 2022. Token mapping is a foundational piece of work to support Government to identify how crypto assets and\nrelated services ought to be regulated. It will also importantly aid the development of a licensing framework\nby assisting in demarcating the perimeter between financial product crypto assets (already the subject of\nfinancial services laws) and non-financial product crypto assets (that may warrant a separate crypto asset\nregulatory framework). Parliament House Canberra ACT 2600 Australia\nOFFICIAL: Sensitive OFFICIAL: Sensitive Subject to your agreement, I propose to announce the reform agenda, commence stakeholder consultations\nand release a public consultation paper on token mapping in 2022 (as indicated in Treasury's earlier\nconsultation paper on crypto licensing and custody requirements)."}, {"chunk_id": "e6bb47e92e88e16c::37a::29f6", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 12, "passage": "16. After token mapping, licensing and custody reforms are the logical next step for crypto reforms\nin Australia. The identification of appropriate obligations and operational standards for crypto\nasset service providers and how they safe-keep assets for customers is a key step for consumer\nprotection; ensuring consumers do not lose assets to avoidable business failure or misuse of\nassets by the provider.\n\n17. The Government will release a consultation paper proposing a licensing and custody framework\nfor crypto asset service providers in mid-2023 to allow for sufficient consultation prior to the\nintroduction of legislation. The paper will reflect ongoing work and consultation in this area and\nleverage the findings from the token mapping exercise. The responses to the following\nquestions will help inform the general direction of future policy and potential consumer\nprotections."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "The Australian Treasury DAP passages describe a domestic reform agenda focused on 'token mapping' to identify how crypto assets fit into the existing financial services framework and the subsequent development of a licensing framework (chunk_ids: d75262e404517e0c::4f1::4905, e6bb47e92e88e16c::37a::29f6). In contrast, the Singapore Foundational Legislation passages discuss MAS's enforcement actions against specific ICO issuers and exchanges, and its intention to expand the scope of legislation to align with international AML/CFT requirements (chunk_ids: b49627bb889ef1d9::3ef::7168, 7c04f2a0bd85290a::413::fc6a). The regimes regulate different aspects of the crypto ecosystem—Australia focuses on the perimeter and licensing framework, while Singapore focuses on enforcement and AML/CFT alignment—and there is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:4abb9b065482b66729b211aa", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}], "rationale": "AU_TREASURY_DAP (Australia's proposed Digital Asset Platforms regime — Treasury consultation) and EU_MICA (EU framework for crypto-asset services). Both regulate crypto-asset service provision in their respective jurisdictions, with materially different mechanisms — AU's proposed DAP framework vs EU's CASP authorisation under MiCA. Distinct perimeters; no obligation conflict on the cited passages."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:53:48Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:4cdf581bf72c26afe3d846db", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "rationale": "The AU_FEDREG_AML regime regulates reporting entities' obligations to identify customers and report suspicious transactions (chunk cf7cefacba3f94bc::49a::f39e). The EU_REVERSE_SOLICITATION regime addresses the conditions under which third-country crypto-asset firms can provide services to EU clients without authorisation when the client initiates the relationship (chunk 25cbbd878a1b21d3::4f8::561c). The obligations in the Australian regime relate to AML/CTF compliance and customer identification, while the EU regime concerns the scope of authorisation for crypto-asset services. These are distinct regulatory domains; the EU reverse solicitation exemption does not impose an AML identification obligation on the third-country firm that conflicts with the Australian reporting entity obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:37:19Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:7a026fb5fd26707d6b307e1b", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}, {"chunk_id": "abc2247bc6415d1d::5c7::68f5", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 10, "passage": "You should obtain the sum of the absolute values of\nexempt supplies from each category to report in your GST return. Category of exempt supplies Exchange gain (loss) for digital\nfor the accounting period from payment tokens\nJan 2020 to Mar 2020\nExchange gain (loss) for digital (200)\npayment tokens Exchange gain (loss) for foreign 400\ncurrency\nInterest received from deposit with 300\nbanks\nValue of exempt supplies |(200)| + 400 + 300\n= $900\nQ9 Can I report the value of supply of digital payment tokens issued during\nmy ICO based on the proceeds received, and then report the value of\nsupply for subsequent transactions based on realised gain or loss? A9 Yes, you may report the proceeds received as the value of supply for ICO\ntransactions. For subsequent exchanges of the tokens for fiat currency or\nother digital payment tokens, you may choose to report the realised gain or\nloss. This is allowed as long as you apply the method chosen consistently.\n14 Contact information\n10.1 For enquiries on this e-Tax Guide, please contact the Goods and Services\nTax Division at www.iras.gov.sg (select \"Contact Us\")\n15 Updates and Amendments\nDate of\nAmendments made\namendment\n1 3 Aug 2022 • Editorial changes.\n• Amended paragraphs 3.6 and 3.8 to reflect the\ndefinition in Income Tax e-Tax Guide on digital\npayment tokens.\n• Added paragraph 5.11 to clarify that if a digital\npayment token is listed on an exchange, IRAS will\nregard the token as suitable for use as a medium\nof exchange."}], "rationale": "The EU_MAR passages regulate market integrity, specifically insider dealing and market manipulation (chunks 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The SG_IRAS_TAX passages regulate tax obligations, specifically the Goods and Services Tax (GST) treatment of digital payment tokens (chunks abc2247bc6415d1d::41e::b184, abc2247bc6415d1d::5c7::68f5). The obligations in EU_MAR relate to the conduct of trading and the prevention of market abuse, whereas the obligations in SG_IRAS_TAX relate to the tax treatment of digital assets. These are distinct regulatory domains; the tax treatment of tokens does not create a conflict with the prohibition of market abuse. Therefore, the regimes are in non_conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.82, "record_type": "conflict", "pair_id": "conflict:0aeaa67c929fd2f74604c6c9", "label": "conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "AU_PRIVACY (APP 8 cross-border disclosure restrictions) and SG_AML (MAS Notice 314 AML/CFT framework — training and reporting obligations). When AU entities collect and share data with SG counterparties under AML obligations, APP 8 engages. Operationally resolvable via APP 6.2(b) plus APP 8.2(d) permitted general situations. Same cross-jurisdictional AML-privacy shape.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:01Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:35:08Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:e9bb1b82e90b9879c290b5d0", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "66d049e24f0863da::3f7::aec8", "source_doc": "Superannuation-Reporting-Standards-RIS.pdf", "page": 1, "passage": "1 INTRODUCTION\nThis Regulation Impact Statement (RIS) addresses the Australian Prudential Regulation\nAuthority's (APRA's) proposed introduction of new reporting standards applying to trustees of\nregistrable superannuation entities (RSE licensees). APRA is the prudential regulator of the superannuation, banking and insurance industries. Its\nmission is to ensure that, under all reasonable circumstances, financial promises made by APRA-\nregulated institutions are met within a stable, efficient and competitive financial system. APRA\ncarries out this mission through a multi-layered prudential framework that encompasses\nlicensing and supervision of institutions. For many years, APRA has had the power to make\nprudential standards implementing this framework for the banking and insurance industries. APRA is also empowered to make reporting standards under the Financial Sector (Collection of\nData) Act 2001 (FSCODA), which require regulated institutions to submit specified data through\nvarious reporting forms."}], "evidence_b": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}], "rationale": "The AU_APRA_PRUDENTIAL regime regulates prudential standards and reporting obligations for financial institutions (ADIs, insurers, RSE licensees) to ensure financial stability and resilience (chunk 66d049e24f0863da::3f7::aec8). The EU_DAC8 regime regulates the automatic exchange of information regarding crypto-asset users for tax compliance purposes (chunk c0300673081f7232::320::7b46). The obligations in the prudential framework relate to capital adequacy, risk management, and financial system stability, whereas the obligations in DAC8 relate to tax transparency and administrative cooperation. The two regimes regulate distinct domains—prudential supervision versus tax administration—and do not impose conflicting obligations on the same entities or transactions."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.82, "record_type": "conflict", "pair_id": "conflict:2f3bd24474c9ed516df246ee", "label": "conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "conflict_type": "structural_unresolved", "severity": "high", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "EU_EMD2 (EU E-Money Directive 2 — EMI authorisation) and SG_STABLECOIN (MAS's Single-Currency Stablecoin framework — Singapore-issued G10 stablecoin issuer authorisation). Both regulate stablecoin-like instrument issuance under different jurisdictional frameworks with materially incompatible authorisation requirements. The SG SCS framework specifically requires Singapore issuance and Singapore-resident regulatory perimeter; EU EMD2 authorisation does not transit. Structural conflict.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:02Z", "decision": "accept", "notes": "", "original_conflict_type": "structural_unresolved", "original_severity": "high", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:03:33Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:ce5a7ef63586487bbdc0b7ad", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}, {"chunk_id": "c51ad46265cea4e5::361::e378", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 16, "passage": "57. ESMA is mandated in Article 84(4) of MiCA to develop, in close cooperation with EBA,\ndraft regulatory technical standards (RTS) on the detailed content of the information for\nthe assessment of proposed acquisitions of qualifying holdings in CASPs. The aim of\nthis draft RTS is to specify the detailed content of the information that direct or indirect\nproposed acquirers must provide to national competent authorities (NCAs) when\nnotifying the intended acquisition. This should ensure a harmonised approach to the\nassessment across Member States in the EU of the intended acquisition of qualifying\nholdings in CASPs.\n\n58. The RTSs are applicable to proposed acquirers of qualifying holdings in CASPs, as well\nas NCAs as designated under Article 93(1) of MiCA that will conduct the assessment of\nthe intended acquisition in accordance with Article 83(4) of MiCA."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The EU MiCA RTS passages regulate the notification requirements and acquisition assessments for Crypto-asset service providers (CASP) and financial entities (chunk_ids c51ad46265cea4e5::2f5::4513 and c51ad46265cea4e5::361::e378). The INT_BASEL_CRYPTO passages regulate capital requirements, risk weighting, and exposure definitions for banks and financial institutions (chunk_ids 32afd37cade34f84::3a4::1a5b and 32afd37cade34f84::3ec::a3fa). The obligations in MiCA regarding crypto-asset service provision and notification do not impose conflicting capital requirements or operational constraints on banks; rather, they address distinct regulatory domains (crypto-asset service provision vs. banking capital adequacy). Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:39:00Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:83ae1991a0e1d034a546e9fa", "label": "non_conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "SG_MAS_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}], "evidence_b": [{"chunk_id": "a82833dc0f7ca903::5f1::735d", "source_doc": "Outsourcing_Guidelines_2018.pdf", "page": 25, "passage": "5.10.2 Material outsourcing arrangements with service providers located outside Singapore\nshould be conducted in a manner so as not to hinder MAS' efforts to supervise the Singapore\nbusiness activities of the institution (i.e., from its books, accounts and documents) in a timely\nmanner, in particular:\n(a) An institution should, in principle, enter into outsourcing arrangements only\nwith service providers operating in jurisdictions that generally uphold\nconfidentiality clauses and agreements.\n\n(b) An institution should not enter into outsourcing arrangements with service\nproviders in jurisdictions where prompt access to information by MAS or\nagents appointed by MAS to act on its behalf, at the service provider, may\nbe impeded by legal or administrative restrictions. An institution must at\nleast commit to retrieve information readily from the service provider\nshould MAS request for such information. The institution should confirm in\nwriting to MAS, that the institution has provided, in its outsourcing\nagreements, for MAS to have the rights of inspecting the service provider,\nas well as the rights of access to the institution and service provider's\ninformation, reports and findings related to the outsourcing arrangement,\nas set out in paragraph 5.9.\n(c) An institution should notify MAS if any overseas authority were to seek\naccess to its customer information or if a situation were to arise where the\nrights of access of the institution and MAS set out in paragraph 5.9, have\nbeen restricted or denied."}], "rationale": "The EU GDPR passages discuss the legal basis for processing, data transfers to third countries, and security measures for payment services. The SG_MAS_OUTSOURCING passages discuss the supervision of Singapore business activities, material outsourcing arrangements with foreign service providers, and the rights of MAS to inspect information. The obligations in the SG_MAS_OUTSOURCING passage (Clause 5.10.2) regarding timely supervision and access to information are complementary to the GDPR's requirements for lawful processing and security, rather than conflicting. The SG_MAS passage does not impose a specific obligation that contradicts the GDPR's data protection principles."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:22:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:197e714278ef4607159e3eca", "label": "non_conflict", "regime_a": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}], "rationale": "The EU regime (Regime A) regulates the specific operational conduct of crypto-asset service providers regarding client solicitation and authorisation exemptions under MiCA. The FATF regime (Regime B) provides general principles for national-level risk assessments and AML/CFT standards, which are not specific obligations regarding solicitation or authorisation. The passages describe different domains of regulation (operational conduct vs. risk assessment framework), and there is no specific obligation in FATF that conflicts with the EU's solicitation rules."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:36:26Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:7d6c5adc1b128465c3bd431d", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DORA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::5f2::974e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 23, "passage": "Article 1\nSubject matter\n1. In order to achieve a high common level of digital operational resilience, this Regulation lays down uniform\nrequirements concerning the security of network and information systems supporting the business processes of financial\nentities as follows:\n(a) requirements applicable to financial entities in relation to:\n(i) information and communication technology (ICT) risk management;\n(ii) reporting of major ICT-related incidents and notifying, on a voluntary basis, significant cyber threats to the\ncompetent authorities;\n(iii) reporting of major operational or security payment-related incidents to the competent authorities by financial\nentities referred to in Article 2(1), points (a) to (d);\n(iv) digital operational resilience testing;\n(v) information and intelligence sharing in relation to cyber threats and vulnerabilities;\n(vi) measures for the sound management of ICT third-party risk;\n(b) requirements in relation to the contractual arrangements concluded between ICT third-party service providers and\nfinancial entities;\n(c) rules for the establishment and conduct of the Oversight Framework for critical ICT third-party service providers when\nproviding services to financial entities;\n(d) rules on cooperation among competent authorities, and rules on supervision and enforcement by competent\nauthorities in relation to all matters covered by this Regulation.\n2. In relation to financial entities identified as essential or important entities pursuant to national rules transposing"}], "rationale": "The AU_ATO_CRYPTO passage discusses the regulation of crypto assets and tax compliance (chunk_id e6bb47e92e88e16c::567::36c4). The EU_DORA passage outlines requirements for digital operational resilience and ICT risk management for financial entities (chunk_id 85307f9e2a040982::5f2::974e). The obligations in these regimes regulate distinct domains—tax compliance and crypto asset classification versus digital operational resilience and ICT risk management—resulting in no overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:35:42Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9532e55b3a0eb6d8f255ec55", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "rationale": "The AU_TREASURY_DAP passages discuss the Australian government's 'token mapping' exercise to identify how crypto assets fit within the financial services framework and the subsequent development of licensing and custody reforms. The EU_AMLA passages describe the establishment of an Authority for anti-money laundering and countering the financing of terrorism (AMLA) and the cooperation between obliged entities and supervisory authorities under the EU AML/CFT framework. The obligations in the EU regime relate to anti-money laundering and supervisory cooperation, while the Australian regime focuses on the classification and licensing of crypto assets. The two regimes regulate different domains (AML/CFT vs. crypto asset licensing), and there is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:57:44Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:0f7b92a20833a658504457c3", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "66d049e24f0863da::3f7::aec8", "source_doc": "Superannuation-Reporting-Standards-RIS.pdf", "page": 1, "passage": "1 INTRODUCTION\nThis Regulation Impact Statement (RIS) addresses the Australian Prudential Regulation\nAuthority's (APRA's) proposed introduction of new reporting standards applying to trustees of\nregistrable superannuation entities (RSE licensees). APRA is the prudential regulator of the superannuation, banking and insurance industries. Its\nmission is to ensure that, under all reasonable circumstances, financial promises made by APRA-\nregulated institutions are met within a stable, efficient and competitive financial system. APRA\ncarries out this mission through a multi-layered prudential framework that encompasses\nlicensing and supervision of institutions. For many years, APRA has had the power to make\nprudential standards implementing this framework for the banking and insurance industries. APRA is also empowered to make reporting standards under the Financial Sector (Collection of\nData) Act 2001 (FSCODA), which require regulated institutions to submit specified data through\nvarious reporting forms."}], "evidence_b": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}], "rationale": "The APRA passage describes a prudential regulatory framework focused on financial stability, licensing, and supervision of institutions (e.g., ADIs, insurers) [66d049e24f0863da::3f7::aec8]. The GDPR passage outlines the legal basis for processing personal data, including conditions for lawful processing and the protection of natural persons [bd84e63f5b622b73::6a8::d132]. The obligations in APRA relate to financial risk management and capital adequacy, while GDPR obligations relate to data privacy and protection. The regimes regulate distinct domains (financial prudential regulation vs. data protection), and there is no evidence of a specific obligation in APRA that conflicts with a specific obligation in GDPR."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f90092ee8d56efdb76da195f", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "EU_AMLR_TFR (regime A) and SG_MAS_AML_GENERAL (regime B) both apply AML/CFT obligations to crypto-asset service providers / DPT providers in their respective jurisdictions. Both implement the same underlying FATF standards. The A passage describes the EU framework extending AML/CFT to CASPs; the B passage describes MAS's risk-based supervision of DPT providers. The obligations reinforce each other (entities operating across both jurisdictions face complementary, not contradictory, AML duties)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:47:08Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:682f82a3fafb861cef2202fa", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}], "rationale": "The AU_AML_CTF regime focuses on reporting obligations for suspicious matters and threshold transactions (chunk 254ca2d92d196180::2ac::a5fe). The EU_PSD2 regime focuses on technical security standards for payment services, specifically strong customer authentication (SCA) and security credentials (chunk adb1a81b9cecaf8c::64f::f5ad). The obligations in the AU regime relate to the detection and reporting of financial crime, while the obligations in the EU regime relate to the technical security of payment transactions. There is no specific obligation in the AU regime that pushes against a specific obligation in the EU regime; they regulate distinct aspects of the financial ecosystem."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:34:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:9812379fc8176d54f69a3ed5", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "66d049e24f0863da::3f7::aec8", "source_doc": "Superannuation-Reporting-Standards-RIS.pdf", "page": 1, "passage": "1 INTRODUCTION\nThis Regulation Impact Statement (RIS) addresses the Australian Prudential Regulation\nAuthority's (APRA's) proposed introduction of new reporting standards applying to trustees of\nregistrable superannuation entities (RSE licensees). APRA is the prudential regulator of the superannuation, banking and insurance industries. Its\nmission is to ensure that, under all reasonable circumstances, financial promises made by APRA-\nregulated institutions are met within a stable, efficient and competitive financial system. APRA\ncarries out this mission through a multi-layered prudential framework that encompasses\nlicensing and supervision of institutions. For many years, APRA has had the power to make\nprudential standards implementing this framework for the banking and insurance industries. APRA is also empowered to make reporting standards under the Financial Sector (Collection of\nData) Act 2001 (FSCODA), which require regulated institutions to submit specified data through\nvarious reporting forms."}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "The evidence for AU_APRA_PRUDENTIAL focuses on the Australian prudential framework, specifically the licensing and supervision of banking, insurance, and superannuation entities (chunk_id 66d049e24f0863da::3f7::aec8). The evidence for SG_FSMA_DTSP focuses on the licensing of Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022 in Singapore (chunk_id cc1be49e9cf8c821::2f4::ea8f). The obligations described in the passages regulate distinct sectors (traditional banking/insurance vs. digital token services) and distinct jurisdictions (Australia vs. Singapore). There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:12:41Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:e24a0e07eb64762939ba29a5", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "rationale": "The AU Travel Rule passages describe a proposed regulatory expansion to implement the FATF Travel Rule for digital currency exchanges, which is currently in consultation and not yet implemented (cf7cefacba3f94bc::383::7d9d, 30a32a386d15ba2b::4f3::edc3). The EU DAC8 passages describe the mandatory automatic exchange of information on crypto-asset users to tax authorities (c0300673081f7232::320::7b46, c0300673081f7232::498::163c). The obligations are distinct: one is a prospective AML/CTF reporting requirement for service providers, while the other is a tax information exchange obligation for operators. There is no evidence of a direct conflict between the two regimes in the provided text."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:21:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:994a9ea9f812e8e31eeebb0a", "label": "non_conflict", "regime_a": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}], "rationale": "The EU regime (Regime A) regulates the specific operational conduct of crypto-asset service providers (CASPs) regarding client solicitation and authorisation requirements under MiCA. The FATF regime (Regime B) establishes a minimum global standard for defining Virtual Asset Service Providers (VASPs) and their AML/CFT obligations. The passages show that the FATF definition of VASP is intended to broaden applicability to new asset types and service providers (chunk_id 85240528438654b9::1cd::07d7), whereas the EU regime focuses on the specific exemption of reverse solicitation for third-country firms (chunk_id 25cbbd878a1b21d3::4f8::561c). There is no specific obligation in the FATF text that conflicts with the EU's reverse solicitation exemption; rather, the FATF provides a definition that the EU regime applies to. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:30:28Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:c5bf5fc4967fbd96db1903ac", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}, {"chunk_id": "33d059aa86716ddd::4ed::8511", "source_doc": "2022_CP_Stablecoin_Regulatory_Approach.pdf", "page": 6, "passage": "3.5 A wide range of stablecoins currently exist, varying in terms of their asset-\npegging, as well as the mechanism that upholds the stability of the stablecoins' value\nagainst the pegged asset(s). MAS intends to focus its regulatory regime on:\nSingle-currency pegged stablecoins (SCS) - As compared to other types of\nstablecoins (such as those pegged to a basket of currencies or other\nassets such as commodities), SCS has a stronger use case for payment and\nsettlement.\nNon-SCS will continue to be subject to the existing DPT regime under the\nPS Act. MAS views such stablecoins as being less stable in nominal value\nand should be treated differently from SCS.\nIn addition, even among SCS, there is variation in the stabilisation\nmechanism. MAS views stablecoins which are algorithmically-pegged,\nunbacked or backed by other cryptocurrencies to be more susceptible to\nvolatility in value. Correspondingly, such stablecoins will also continue to\nbe treated as DPTs.\nSCS issued in Singapore - The immediate priority of MAS is to elevate the\nstandard of SCS issued in Singapore. Our regulatory perimeter is thus\nscoped based on MAS' ability to directly impose requirements on the\nreserve management, redemption policies and prudential standards of\nthe SCS issuer."}], "rationale": "The AU_TTR_THRESHOLD regime regulates the reporting of physical cash transfers exceeding A$10,000 (chunk_ids 6dfe4e63b9fb3c74::3bc::1a3f, 254ca2d92d196180::377::d0c6). The SG_STABLECOIN regime regulates the issuance and reserve requirements of Single-Currency Stablecoins (SCS) issued in Singapore (chunk_ids 58f45cd2ef3de201::36c::e2f6, 33d059aa86716ddd::4ed::8511). The obligations are distinct: one focuses on physical cash reporting thresholds, while the other focuses on the tokenization of assets and reserve management. There is no specific obligation in the SG_STABLECOIN regime that conflicts with the AU_TTR_THRESHOLD reporting requirement. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:40:47Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:3a7a963962f60e2fbfa4f53f", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "rationale": "The EU_NIS2 passage discusses the preparation of technical standards and guidelines for access control policies and ICT security measures (chunk_id 3c9eb3a25c93f394::474::4786). The INT_BASEL_GENERAL passage discusses the treatment of fiduciary assets and general provisions for leverage ratio exposure measures (chunk_id 32afd37cade34f84::34b::8d30). The obligations and subject matter of the two regimes are distinct; one concerns cybersecurity and access controls, while the other concerns banking capital adequacy and leverage ratios. There is no specific obligation in NIS2 that conflicts with a specific obligation in Basel regarding the same subject matter."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:c605b5d5ed9d2a394fa1f930", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "a0d157539d5c8040::2fc::beb4", "source_doc": "FinalReport_Market_Abuse_Guidelines_MiCA.pdf", "page": 6, "passage": "2 Background and Legal Basis\nArticle 92 (3) of MiCA:\nIn order to ensure consistency of supervisory practices under this Article, ESMA shall by 30\nJune 2025 issue guidelines in accordance with Article 16 of Regulation (EU) No 1095/2010 on\nsupervisory practices among the competent authorities to prevent and detect market abuse, if\nnot already covered by the regulatory technical standards referred to in paragraph 2.\n\n1. To promote confidence in markets in crypto-assets and ensure their integrity, Title VI of\nMiCA lays down rules on prevention and prohibition of market abuse involving crypto\nassets.\n\n2. Article 92(1) of MiCA requires any PPAET in crypto-assets to have in place effective\narrangements, systems and procedures to prevent and detect market abuse."}], "evidence_b": [{"chunk_id": "ba862e1f095bceac::1a6::1f0e", "source_doc": "FATF Recommendations 2012.pdf.coredownload.inline.pdf", "page": 79, "passage": "4. A country need not impose a separate licensing or registration system with respect to natural\nor legal persons already licensed or registered as financial institutions (as defined by the FATF\nRecommendations) within that country, which, under such license or registration, are\npermitted to perform VASP activities and which are already subject to the full range of\napplicable obligations under the FATF Recommendations."}], "rationale": "EU_MICA (EU crypto-asset regulation, market abuse guidelines per Article 92) and INT_FATF_VASP (FATF guidance for VASPs). EU MiCA includes AML/CFT obligations that align with FATF VASP standards; MiCA-authorised CASPs ARE FATF VASPs and face both regulatory frameworks. The B passage notes FATF allows existing licensed financial institutions to perform VASP activities without separate registration — aligned with MiCA's CASP-authorisation approach. Reinforcing rather than conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:15:50Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b99d14f44c3ebab9aafdc05d", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "66d049e24f0863da::3f7::aec8", "source_doc": "Superannuation-Reporting-Standards-RIS.pdf", "page": 1, "passage": "1 INTRODUCTION\nThis Regulation Impact Statement (RIS) addresses the Australian Prudential Regulation\nAuthority's (APRA's) proposed introduction of new reporting standards applying to trustees of\nregistrable superannuation entities (RSE licensees). APRA is the prudential regulator of the superannuation, banking and insurance industries. Its\nmission is to ensure that, under all reasonable circumstances, financial promises made by APRA-\nregulated institutions are met within a stable, efficient and competitive financial system. APRA\ncarries out this mission through a multi-layered prudential framework that encompasses\nlicensing and supervision of institutions. For many years, APRA has had the power to make\nprudential standards implementing this framework for the banking and insurance industries. APRA is also empowered to make reporting standards under the Financial Sector (Collection of\nData) Act 2001 (FSCODA), which require regulated institutions to submit specified data through\nvarious reporting forms."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "The APRA passages describe a prudential framework for banking, insurance, and superannuation entities, focusing on capital requirements, licensing, and supervision (chunk_ids 9a96d4d1812f257a::2a6::2422, 66d049e24f0863da::3f7::aec8). The SG_STABLECOIN passages describe a specific regulatory regime for 'Single Currency Stablecoins' (SCS) issued in Singapore, distinct from other digital payment tokens (chunk_ids 58f45cd2ef3de201::36c::e2f6, 33d059aa86716ddd::4ed::8511). The SG regime explicitly states that non-SCS will continue to be subject to the existing DPT regulatory regime under the Payment Services Act (chunk_id 58f45cd2ef3de201::36c::e2f6). There is no evidence in the provided passages that APRA's prudential standards impose conflicting obligations on entities regulated by the MAS stablecoin framework, nor is there evidence that the MAS stablecoin framework imposes obligations on APRA-regulated entities that would conflict with APRA's prudential standards. The regimes regulate different domains: APRA regulates financial institutions (ADIs, insurers, RSEs) for prudential safety, while MAS regulates specific stablecoin products for market integrity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:e9d2da98c083db0b734003b0", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "601316b5944a8a71::49b::b6c2", "source_doc": "Terrorist-Financing-Risk-Assessment-Guidance.pdf.coredownload.pdf", "page": 35, "passage": "Box 3.1. Potential Use of Financial Intelligence to Assess Cross-border TF\nRisks\nCross-border transaction or movement reports (CTRs) - The FATF\nStandards require that all countries implement a declaration or disclosure\nsystem for incoming and outgoing cross-border transportation of currency\nand bearer negotiable instruments (CBNIs) with a maximum threshold of\nUSD/EUR 15 000 (FATF Recommendation 32.) While the low volume of\nfunds often used by terrorists presents challenges for detection in a\nthreshold-based system, countries to date have found that information on\n40 Notably, chapter 2 above also contains guidance and information sources relevant when assessing\ncross-border TF risks. 34 │ TERRORIST FINANCING RISK ASSESSMENT GUIDANCE\nthe general inflows/outflows of CBNI may still provide useful information\non the potential TF vulnerabilities posed by different borders. Suspicious Transaction Reports (STRs) - The FATF Standards require\nthat all financial institutions and DNFBPs should be required to notify the\nFIU if they suspect or have reasonable grounds to suspect that funds are the\nproceeds of a criminal activity, or are related to TF (FATF Recommendation\n20)."}], "rationale": "AU_AML_CTF (Australian AML/CTF Act — AUSTRAC reporting framework) and INT_FATF_GENERAL (FATF AML/CFT standards — including R32 on cross-border CTRs). The Australian AML/CTF regime explicitly implements FATF standards including threshold and cross-border reporting. Reinforcing."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:07:56Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:8a3c5de91de47b8903bd240a", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4a92930a8caf822::380::0a18", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 12, "passage": "Part 1 Preliminary\nSection 1-4\n(a) in relation to registration or proposed registration of a person under Part 6\nof the Act as a remittance network provider-registrable remittance\nnetwork services; or\n(b) in relation to registration or proposed registration of a person under Part 6\nof the Act as an independent remittance dealer or a remittance affiliate of a\nregistered remittance network provider-registrable remittance services; or\n(c) in relation to registration or proposed registration of a person under Part 6A\nof the Act as a virtual asset service provider-registrable virtual asset\nservices.\nrelated body corporate has the same meaning as in the Corporations Act 2001.\nsuper-agent has the meaning given by subsection 4-13(2).\ntracing information, in relation to a transfer of value, means information that\nsatisfies both of the following:\n(a) the information:\n(i) for a transfer from an"}, {"chunk_id": "c4a92930a8caf822::57d::3f76", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 28, "passage": "Part 4-Registration\nDivision 1-Management of the Remittance Sector Register and the\nVirtual Asset Service Provider Register\n4-1 Correction of entries\n(1) This section is made for the purposes of paragraphs 75(4)(a) and 76B(4)(a) of the\nAct. (2) If the AUSTRAC CEO reasonably believes that there is an error in, or omission\nfrom, an entry in the Remittance Sector Register or the Virtual Asset Service\nProvider Register, the AUSTRAC CEO may correct the error or omission. (3) As soon as reasonably practicable after making a correction of an entry under\nthis section, the AUSTRAC CEO must give notice of the correction to:\n(a) the person whose registration the entry relates to; and\n(b) if the registration is of a person as a remittance affiliate of a registered\nremittance network provider-the provider.\n4-2 Publication of register information\n(1) For the purposes of subsections 75(4) and 76B(4) of the Act, the AUSTRAC\nCEO must publish the following on AUSTRAC's website:\n(a) the details mentioned in paragraphs 75A(1)(a), (b), (c) and (f) of the Act on\nthe Remittance Sector Register;\n(b) the details mentioned in paragraphs 76C(a) and (d) of the Act on the\nVirtual Asset Service Provider Register;\n(c) information mentioned in section 4-24 of this instrument (register entry in\nrelation to suspension of registration) on the Remittance Sector Register\nand the Virtual Asset Service Provider Register."}, {"chunk_id": "c4a92930a8caf822::37f::8a4f", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 98, "passage": "mentioned in item 2 (ii) tracing information\ndo not apply\n4 the transfer of value is a merchant payment card number of the card the payer used in\nrelation to the merchant payment\n5 the transfer of value is a refund of a card number of the card the payer used in\nmerchant payment relation to the merchant payment that is\nrefunded\n6 the instruction for the transfer of value is card number of the card the payer used in\ngiven by the use of an ATM relation to the withdrawal\n7 (a) the value being transferred is money; and tracing information\n(b) the money is in a foreign country and, as\na result of the provision of an\ninternational value transfer service, the\nmoney will be in Australia; and\n(c) the beneficiary institution receives the\ntransfer message for the transfer of value\nthrough BECS\n8 the value is transferred from a self-hosted (a) payer information; and\nvirtual asset wallet (b) the"}, {"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::5c7::68f5", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 10, "passage": "You should obtain the sum of the absolute values of\nexempt supplies from each category to report in your GST return. Category of exempt supplies Exchange gain (loss) for digital\nfor the accounting period from payment tokens\nJan 2020 to Mar 2020\nExchange gain (loss) for digital (200)\npayment tokens Exchange gain (loss) for foreign 400\ncurrency\nInterest received from deposit with 300\nbanks\nValue of exempt supplies |(200)| + 400 + 300\n= $900\nQ9 Can I report the value of supply of digital payment tokens issued during\nmy ICO based on the proceeds received, and then report the value of\nsupply for subsequent transactions based on realised gain or loss? A9 Yes, you may report the proceeds received as the value of supply for ICO\ntransactions. For subsequent exchanges of the tokens for fiat currency or\nother digital payment tokens, you may choose to report the realised gain or\nloss. This is allowed as long as you apply the method chosen consistently.\n14 Contact information\n10.1 For enquiries on this e-Tax Guide, please contact the Goods and Services\nTax Division at www.iras.gov.sg (select \"Contact Us\")\n15 Updates and Amendments\nDate of\nAmendments made\namendment\n1 3 Aug 2022 • Editorial changes.\n• Amended paragraphs 3.6 and 3.8 to reflect the\ndefinition in Income Tax e-Tax Guide on digital\npayment tokens.\n• Added paragraph 5.11 to clarify that if a digital\npayment token is listed on an exchange, IRAS will\nregard the token as suitable for use as a medium\nof exchange."}, {"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}, {"chunk_id": "7c5602f8b898a7ab::277::e4ae", "source_doc": "Income_Tax_Treatment_of_Digital_Tokens.pdf", "page": 10, "passage": "12.1 Taxpayers should keep proper records of transactions and provide them to\nIRAS upon request. These supporting records should include information\nsuch as:\n• Date of transaction\n• Number of units of digital tokens received or sold\n• Value of digital token at the time of the transaction\n• Exchange rate used\n• Purpose of the transaction\n• Details of customers/suppliers (for buy-sell transactions)\n• Details of the ICO\n• Receipts/invoices of business expenses\n\n13. Contact Information\n\n13.1 For general enquiries or clarifications on this e-Tax Guide, please call 1800-\n356 8622 (Corporate Tax) or 1800-356 8300 (Individual Tax)."}], "rationale": "The AU_TRAVEL_RULE passages discuss the Australian regulatory framework for remittance networks and virtual asset service providers, specifically referencing the FATF 'Travel Rule' and AML/CTF obligations (chunk_ids c4a92930a8caf822::380::0a18, c4a92930a8caf822::57d::3f76, cf7cefacba3f94bc::383::7d9d, 30a32a386d15ba2b::4f3::edc3). In contrast, the SG_IRAS_TAX passages focus on Singapore's tax treatment of digital payment tokens, specifically GST treatment and record-keeping requirements (chunk_ids abc2247bc6415d1d::5c7::68f5, abc2247bc6415d1d::41e::b184, 7c5602f8b898a7ab::277::e4ae). The obligations in the AU regime relate to anti-money laundering compliance and the identification of parties in transfers, while the obligations in the SG regime relate to goods and services tax and record-keeping for token transactions. These are distinct regulatory domains with no apparent overlap or conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:02:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f38f43d41c3e59a2e527edd6", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "66d049e24f0863da::3f7::aec8", "source_doc": "Superannuation-Reporting-Standards-RIS.pdf", "page": 1, "passage": "1 INTRODUCTION\nThis Regulation Impact Statement (RIS) addresses the Australian Prudential Regulation\nAuthority's (APRA's) proposed introduction of new reporting standards applying to trustees of\nregistrable superannuation entities (RSE licensees). APRA is the prudential regulator of the superannuation, banking and insurance industries. Its\nmission is to ensure that, under all reasonable circumstances, financial promises made by APRA-\nregulated institutions are met within a stable, efficient and competitive financial system. APRA\ncarries out this mission through a multi-layered prudential framework that encompasses\nlicensing and supervision of institutions. For many years, APRA has had the power to make\nprudential standards implementing this framework for the banking and insurance industries. APRA is also empowered to make reporting standards under the Financial Sector (Collection of\nData) Act 2001 (FSCODA), which require regulated institutions to submit specified data through\nvarious reporting forms."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "The evidence from APRA (Regime A) focuses on the prudential framework, licensing, and supervision of financial institutions (ADIs, insurers, RSE licensees) and reporting standards under the Financial Sector (Collection of Data) Act 2001 (FSCODA) [66d049e24f0863da::3f7::aec8]. The evidence from MAS (Regime B) concerns the Payment Services Act 2019, specifically the licensing of Digital Payment Token (DPT) service providers and AML/CFT obligations [4b4c3c417dc293ba::185::f41d]. The obligations in Regime A relate to prudential capital, risk management, and reporting for traditional financial institutions, while Regime B regulates the licensing and conduct of DPT service providers. These are distinct regulatory domains with no apparent overlap of obligations between the specific prudential standards of APRA and the payment services licensing requirements of MAS."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:24:37Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:7baf9658005fd169d82f9137", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::41f::546c", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 24, "passage": "3.1 Standard AFSL Obligations\nAustralian financial services licence\n(a) A platform provider must hold an AFSL authorising them to issue and deal in digital asset facilities.\n(b) A platform provider is exempt from holding an AFSL for digital asset facilities if:\n(i) the total value of platform entitlements held by any one client of the platform provider does\nnot exceed $1,500 at any one time; and\n(ii) the total amount of assets held by the platform provider does not exceed $5 million at any\ntime.\nInfo Box 3 Low value exemption\nThe risks with digital asset facilities are correlated to the size and scale of the asset holding role of\nthe platform provider. Accordingly, a 'low-value facility' exemption would be introduced, similar to\nthe 'low value facility' exemption for non-cash payment facilities. It would apply to digital asset\nfacilities holding less than $1,500 per customer and less than $5 million in total.40 This exemption\nis intended to allow for innovation and experimentation in the early stages of developing a novel\nservice offering."}, {"chunk_id": "550958b067dc6726::74a::7ef1", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 26, "passage": "46 For information on ASIC's interpretation of this obligation, see ASIC PF 209 Australian financial services\nlicence conditions\nLicensing digital asset intermediaries | 23\n\n(vi) having the financial,47 technological, and human resources to carry out and supervise the\nfinancial service covered by the AFSL,\n(vii) having a dispute resolution system48 and compensation arrangements for retail clients for\nloss or damage suffered due to breaches of obligations, and\n(viii) maintaining a risk management system.\nFinancial requirements\n(g) A platform provider must meet:\n(i) the standard solvency and positive net asset requirements,49\n(ii) the standard cash needs requirement, and\n(iii) a net tangible assets (NTA) requirement for holding cash or cash equivalents and holding\nliquid assets of at least:\n• 0.5 per cent of the value of the facility (if using a sub-custodian digital asset facility that\nhas $5m NTA),50 or\n• $5 million (if performing the custody function).\nInfo Box 6 Financial requirements\nAFSL holders have obligations to meet 'financial requirements'. These requirements are typically\ntailored for different financial products through ASIC legislative instruments. The NTA obligation is\nto address the costs of orderly wind-up in the event the provider fails.51\nA key issue with digital assets is concentration risk (see Info Box 11 Additional Standards for token\nholders). The proposed financial requirements balance the need to avoid concentration of digital\nassets among a small number of custodians with the need to ensure robust NTA. It sets the\nrequired level of NTA at the greater of $5 million or 0.5% of the value of the assets held by the\nfacility.52 This arrangement ensures that as a facility expands, and the operational risk exposure of\nthe platform provider grows, the provider will maintain a corresponding level of financial\nresources."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}, {"chunk_id": "39886a6842407c92::356::ee53", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 6, "passage": "3.1 This Notice is based on the following principles, which shall serve as a guide for all banks\nin the conduct of their operations and business activities:\n(a) A bank shall exercise due diligence when dealing with customers, natural persons\nappointed to act on the customer's behalf, connected parties of the customer and\nbeneficial owners of the customer.\n(b) A bank shall conduct its business in conformity with high ethical standards, and\nguard against establishing any business relations or undertaking any transaction,\nincluding a digital token transaction, that is or may be connected with, or facilitates\nor may facilitate money laundering or terrorism financing.\n(c) A bank shall, to the fullest extent possible, assist and cooperate with the relevant\nlaw enforcement authorities in Singapore to prevent money laundering and\nterrorism financing."}], "rationale": "The AU_ASIC_AFSL regime regulates the licensing and conduct of financial services providers (specifically platform providers and intermediaries) dealing in digital asset facilities, including financial requirements and AFSL obligations (chunk_ids 550958b067dc6726::41f::546c, 550958b067dc6726::74a::7ef1). The SG_AML regime regulates AML/CFT obligations for financial institutions, including banks and insurers, focusing on customer due diligence, suspicious transaction reporting, and training (chunk_ids 3d521e61e49aaf46::38f::e615, 39886a6842407c92::356::ee53). While both regimes apply to entities dealing with digital assets, they regulate distinct aspects: one governs the financial services license and operational conduct, while the other governs anti-money laundering compliance and risk management. There is no specific obligation in the AFSL regime that directly conflicts with or negates the AML obligations in the SG_AML regime; rather, they are complementary requirements for operating in the digital asset space."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:6b9406be2e5983c1de7b78ab", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 230"}, "regime_b": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU Privacy"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}, {"chunk_id": "6c3ed2e60520c185::546::b286", "source_doc": "Privacy_Act_1988.pdf", "page": 376, "passage": "Part 1-Consideration of personal information\nprivacy\n1 Australian Privacy Principle 1-open and transparent\nmanagement of personal information\n1.1 The object of this principle is to ensure that APP entities manage\npersonal information in an open and transparent way. Compliance with the Australian Privacy Principles etc.\n1.2 An APP entity must take such steps as are reasonable in the\ncircumstances to implement practices, procedures and systems\nrelating to the entity's functions or activities that:\n(a) will ensure that the entity complies with the Australian\nPrivacy Principles and a registered APP code (if any) that\nbinds the entity; and\n(b) will enable the entity to deal with inquiries or complaints\nfrom individuals about the entity's compliance with the\nAustralian Privacy Principles or such a code. APP Privacy policy\n1.3 An APP entity must have a clearly expressed and up-to-date policy\n(the APP privacy policy) about the management of personal\ninformation by the entity.\n1.4 Without limiting subclause 1.3, the APP privacy policy of the APP\nentity must contain the following information:\n(a) the kinds of personal information that the entity collects and\nholds;\n(b) how the entity collects and holds personal information;\n(c) the purposes for which the entity collects, holds, uses and\ndiscloses personal information;\n358 Privacy Act 1988"}], "rationale": "CPS 230 is APRA's prudential operational-risk management standard (critical operations, BCP, service-provider risk). The Privacy Act / APPs govern personal-information handling. The two regimes apply to APRA-regulated APP entities but operate in disjoint domains. APP 11 (security of personal information) is incidentally informed by CPS 230 controls, but the obligations are cumulative, not conflicting.", "would_conflict_if": ["CPS 230 third-party reporting required disclosure of personal information that APP 6 would prohibit — outsourcing arrangements typically already include APP-compatible data-handling clauses."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:48:53Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:44f9332b4ef94e30946d37e9", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "0fc4f857c226f510::375::66b5", "source_doc": "Corporations_Act_2001_Vol1.pdf", "page": 296, "passage": "Part 1.6 Interaction with Australian Charities and Not-for-profits Commission Act Section 111L\nProvisions of this Act that do not apply to bodies corporate registered under the\nACNC Act\nItem Column 1 Column 2\nProvision(s) Topic\n2 section 138 ASIC may direct company to lodge\nconsolidated constitution\n3 section 139 Company must send copy of\nconstitution to member\n4 subsection 142(2), section 146 and Company must notify ASIC of\nsubsection 146A(2) changes of address\n5 (a) sections 180 to 183; and Duties of directors etc. (b) section 185, to the extent that it\nrelates to sections 180 to 183\n6 section 188, to the extent it relates to Responsibility of secretaries and\na provision mentioned in another directors for certain contraventions\nitem of this table\n7 sections 191 to 194 Interests of directors\n8 (a) sections 201L and 205A to 205C; Public information about directors\nand etc."}], "evidence_b": [{"chunk_id": "6d8a84a9f3d6e9e4::480::ac46", "source_doc": "Guidelines_to_MAS_Notice_SFA04-N02_2025.pdf", "page": 5, "passage": "2 The FSM Sanctions Regulations include the regulations issued under section 192 read with sections 15(1)(b) and 219(d)\nof the FSM Act. Please refer to the following link for the FSM Sanctions Regulations:\nhttps://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions/regulations-for-targeted-financial-\nsanctions. Currently, the relevant FSM Sanctions Regulations are those relating to the Democratic People's Republic of\nKorea and Iran. concerns. Other support functions such as operations, human resource or\ntechnology also play a role to help mitigate the ML/TF risks that the CMI faces. The AML/CFT compliance function is typically the contact point regarding all\nAML/CFT issues for domestic and foreign authorities, including supervisory\nauthorities, law enforcement authorities and financial intelligence units.\n1-4-14 As the third line of defence, the CMI's internal audit function or an equivalent\nfunction plays an important role in independently evaluating the AML/CFT risk\nmanagement framework and controls for purposes of reporting to the audit\ncommittee of the CMI's board of directors, or a similar oversight body."}], "rationale": "The evidence for AU_CORPS_ACT (chunk 0fc4f857c226f510::375::66b5) outlines the interaction between the Corporations Act and the Australian Charities and Not-for-profits Commission Act, detailing specific provisions regarding company constitutions, director duties, and winding up. The evidence for SG_MAS_AML_GENERAL (chunk 6d8a84a9f3d6e9e4::480::ac46) discusses the FSM Sanctions Regulations and the role of the AML/CFT compliance function within a financial institution. The obligations in the Corporations Act regarding corporate governance and winding up do not overlap with the obligations in the Singapore AML/CFT regime regarding sanctions compliance and internal audit functions. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:47:28Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:84a27841c90c5c5b91a60a3b", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}], "rationale": "The AU_PRIVACY regime regulates the cross-border disclosure of personal information, requiring entities to ensure overseas recipients comply with Australian Privacy Principles (APPs) and providing exceptions for consent or permitted general situations (e.g., safety threats) [e9f6b0a9e797777d::5d6::e5ff, e9f6b0a9e797777d::4ba::1af3]. The EU_MAR regime regulates market abuse, including insider dealing and market manipulation, to ensure financial market integrity [5cc4a27bc578287a::165::3333]. The obligations are distinct: one governs data protection and privacy flows, while the other governs financial market conduct and integrity. There is no specific obligation in AU_PRIVACY that pushes against a specific obligation in EU_MAR, nor is there evidence of overlap in the cited passages. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:46:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:dfb79461860c26972daf6673", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4024f4c4c1616cc::23d::700a", "source_doc": "AMLR_Regulation_EU_2024-1624.pdf", "page": 2, "passage": "(7) Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers\nof funds and certain crypto-assets and amending Directive (EU) 2015/849 (OJ L 150, 9.6.2023, p. 1).\n\n(8) Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing the Authority for\nAnti-Money Laundering and Countering the Financing of Terrorism and amending Regulations (EU) No 1093/2010, (EU)\nNo 1094/2010 and (EU) No 1095/2010 (OJ L, 2024/1620, 19.6.2024, http://data.europa.eu/eli/reg/2024/1620/oj)."}, {"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The EU AMLR TFR regime regulates the traceability of crypto-asset transfers and the obligations of obliged entities (e.g., crypto-asset service providers) to accompany transfers with payer information (c0300673081f7232::279::1918). The INT IOSCO GENERAL regime provides a high-level methodology for securities regulation and disclosure standards, focusing on the objectives and principles of securities regulation and cooperation among securities authorities (f173909614befd49::455::1a1a). The obligations in the EU regime relate to anti-money laundering and transaction traceability, while the IOSCO regime focuses on securities market regulation and disclosure. There is no specific obligation in the EU regime that pushes against a specific obligation in the IOSCO regime; they regulate distinct domains of financial activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:cb7ff4e0e95f243fc750d18c", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "evidence_b": [{"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "EU_NIS2 (EU Network and Information Security Directive — ICT access-control measures) and MAS_TRM (MAS Technology Risk Management guidelines — principles-based ICT/cybersecurity expectations). Both implement cybersecurity / technology-risk frameworks for financial-sector entities in their respective jurisdictions. Aligned in concern (cyber resilience) with different mechanisms."}
+{"annotator_id": 10116, "annotated_at": "2026-06-18T11:48:14Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:332a299af3ad6d21d5852ab1", "label": "conflict", "regime_a": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "SG_MAS_AML_GENERAL"}, "regime_b": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "417228836d7e2aa3::379::317d", "source_doc": "MAS_Notice_PSN02_2024-04-02_rev_2025-06-30.pdf", "page": 2, "passage": "or\n(b) means an FX counterparty;\n\"relevant FX counterparty\" is a FX counterparty that is not ⎯\n(a) a financial institution as defined in section 2 of the FSM Act; or\n(b) a financial institution incorporated or established outside Singapore that is subject\nto, and supervised for compliance with, AML/CFT requirements consistent with\nstandards set by the FATF;\n\"SFA\" means the Securities and Futures Act 2001;\n\"STR\" means suspicious transaction report;\n\"STRO\" means the Suspicious Transaction Reporting Office, Commercial Affairs\nDepartment of the Singapore Police Force;\n\"transaction\" means any transaction accepted, processed, or executed by the payment\nservice provider in the course of carrying on its business of providing a digital payment\ntoken service;\n\"trust relevant party\" has the same meaning as defined in paragraph 2.1 of MAS Notice\nTCA-N03;\n[MAS Notice PSN02 (Amendment) 202"}, {"chunk_id": "d6f4be6b9d136778::4ae::d5ed", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 67, "passage": "27 These offences typically relate to cybersecurity issues such as unauthorised access. addition, MAS' off-site monitoring will also enable us to identify and target specific\nkey risks and initiate supervisory follow-up actions including for-cause inspections\nas necessary. Payment Services Act 2019\nII-3-2 ML/TF risks have been identified as the primary risk concerns posed by virtual\nassets, given the anonymity, speed and cross-border nature of transactions\nfacilitated by virtual asset providers. Under the Payment Services Act 2019 (PS\nAct), MAS will impose AML/CFT requirements on the intermediaries that buy, sell\nor exchange virtual assets in Singapore - these are the VASP business models\nidentified to be operating in Singapore. II-3-3 Under the PS Act, aligned with the FATF standards, DPT service providers are\nrequired to conduct customer due diligence and transaction monitoring measures,\nas well as to report suspicious transactions to the authorities. They are also\nrequired to screen and submit information on their customers when transferring\nDPTs to one another on behalf of their customers, and make this information\navailable on request to appropriate authorities in Singapore."}], "evidence_b": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "rationale": "SG_MAS_AML_GENERAL (MAS AML/CFT framework — FSM Sanctions Regulations and MAS Notices SFA04-N02 + PSN02, requiring SG-licensed entities to collect, retain, and share customer information for AML/CFT compliance, including with foreign counterparties under international cooperation arrangements) and AU_PRIVACY (Australian Privacy Principles, especially APP 8 cross-border disclosure restrictions). When SG-licensed entities serve AU-resident customers and transmit AML data to MAS or counterparty AU institutions, APP 8 obligations engage on the AU side; the AU APP entity must take reasonable steps to ensure overseas-recipient compliance with APPs. Operationally resolvable via APP 6.2(b) (use or disclosure required or authorised by law) plus APP 8.2(d) permitted general situations. Same conflict shape as labelled SG_MAS_AML_GENERAL × EU_GDPR.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:56Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:e9b0f4d93a398b856ec178b0", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EMD2"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "Market Abuse Regulation"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6bbad50f6b09cc9d::27e::94d4", "source_doc": "EMD2_Directive_EU_2009-110.pdf", "page": 6, "passage": "Article 4\ntution to hold an amount of own funds which is up to 20 %\nInitial capital higher than the amount which would result from the appli\ncation of the relevant method in accordance with paragraph\nMember States shall require electronic money institutions to\n2, or permit the electronic money institution to hold an\nhold, at the time of authorisation, initial capital, comprised of\namount of own funds which is up to 20 % lower than the\nthe items set out in Article 57(a) and (b) of Directive\namount which would result from the application of the\n2006/48/EC, of not less than EUR 350 000.\nrelevant method in accordance with paragraph 2."}, {"chunk_id": "6bbad50f6b09cc9d::518::589e", "source_doc": "EMD2_Directive_EU_2009-110.pdf", "page": 5, "passage": "Article 2\nDefinitions\nThe proposed acquirer shall supply to the competent authority\nFor the purposes of this Directive, the following definitions shall\ninformation indicating the size of the intended holding and\napply:\nrelevant information referred to in Article 19a(4) of Directive\n2006/48/EC.\n1. 'electronic money institution' means a legal person that has\nbeen granted authorisation under Title II to issue electronic\nmoney;\nWhere the influence exercised by the persons referred to in the\nsecond subparagraph is likely to operate to the detriment of the\n2. 'electronic money' means electronically, including prudent and sound management of the institution, the\nmagnetically, stored monetary value as represented by a competent authorities shall express their opposition or take\nclaim on the issuer which is issued on receipt of funds for other appropriate measures to bring that situation to an end.\nthe purpose of making payment transactions as defined in Such measures may include injunctions, sanctions against\npoint 5 of Article 4 of Directive 2007/64/EC, and which is directors or managers, or the suspension of the exercise of\naccepted by a natural or legal person other than the elec the voting rights attached to the shares held by the shareholders\ntronic money issuer; or members in question."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::1bd::d04c", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 14\nProhibition of insider dealing and of unlawful disclosure of inside information\nA person shall not:\n(a) engage or attempt to engage in insider dealing;\n(b) recommend that another person engage in insider dealing or induce another person to engage in insider dealing; or\n(c) unlawfully disclose inside information.\n\nArticle 15\nProhibition of market manipulation\nA person shall not engage in or attempt to engage in market manipulation."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "rationale": "EMD2 is an e-money authorisation regime; MAR is a market abuse regulation for financial instruments traded on EU venues. E-money itself is not a financial instrument under MiFID II Annex I Section C, so EMD2 entities are largely outside MAR's substantive scope. Easy hard negative — regimes operate in entirely different domains.", "would_conflict_if": ["E-money were re-classified as a financial instrument under a future MiFID amendment — speculative and not in current text."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:14:51Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:615ff6c7ed53312ae40a8774", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::15a::fbf2", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 80, "passage": "Article 63\nCooperation with AMLA\nFIU and supervisory authorities shall cooperate with AMLA and shall provide it with all the information necessary to allow\nit to carry out its duties under this Directive and under Regulations (EU) 2024/1624 and (EU) 2024/1620.\nSECTION 2\nCooperation with other authorities and exchange of confidential information"}, {"chunk_id": "df546f2364aaf9e2::620::328c", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 79, "passage": "Article 62\nCommunication of the list of the competent authorities\n1. In order to facilitate and promote effective cooperation, and in particular the exchange of information, Member States\nshall communicate to the Commission and AMLA:\n(a) the list of supervisors responsible for overseeing the compliance of the obliged entities with Regulation (EU)\n2024/1624, as well as, where relevant, name of the public authority overseeing self-regulatory bodies in their\nperformance of supervisory functions under this Directive, and their contact details;\n(b) the contact details of their FIU;\n(c) the list of other competent national authorities.\n2. For the purposes of paragraph 1, the following contact details shall be provided:\n(a) a contact point or, failing that, the name and role of a contact person;\n(b) the email and phone number of the contact point or, failing that, the professional email address and phone number of\nthe contact person.\nELI: http://data.europa.eu/eli/dir/2024/1640/oj 79/94\n\nEN\n3. Member States shall ensure that the information provided to the Commission and AMLA pursuant to paragraph 1 is\nupdated as soon as a change takes place.\n4. AMLA shall publish a register of the authorities referred to in paragraph 1 on its website and facilitate the exchange of\ninformation referred to in paragraph 2 between competent authorities. The authorities in the register shall, within the scope\nof their powers, serve as a contact point for the counterpart competent authorities. FIUs and supervisory authorities shall\nalso serve as a contact point for AMLA."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The EU AMLA passages focus on cooperation obligations, information exchange, and the establishment of an authority for anti-money laundering and countering the financing of terrorism (AMLA) [df546f2364aaf9e2::15a::fbf2, df546f2364aaf9e2::620::328c, df546f2364aaf9e2::25a::6ab3]. The INT_BASEL_CRYPTO passages focus on capital requirements, risk-weighting methodologies, and prudential standards for banks and financial institutions [32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3c8::f259, 32afd37cade34f84::3ec::a3fa]. The obligations in the EU AMLA regime (reporting, cooperation, supervision) do not impose specific operational constraints or conflicts with the capital adequacy and risk management standards described in the INT_BASEL_CRYPTO regime. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:20:47Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:3262cf17167aea1b41a3cb15", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}], "rationale": "The evidence from the AU_ATO_CRYPTO regime focuses on token mapping, tax compliance, and general crypto adoption statistics (chunk_id e6bb47e92e88e16c::567::36c4). The evidence from the EU_MICA regime outlines the legal framework for crypto-asset services, including the provision of advice on crypto-assets (chunk_id f9082873c5d9ba9d::302::bbe0). The passages describe distinct regulatory domains: one focuses on Australian tax and token classification, while the other establishes a European Union framework for crypto-asset service provision. There is no specific obligation in one regime that pushes against a specific obligation in the other; rather, they address separate regulatory objectives and scopes."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:20:37Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:bf118b400f8209e8a124e43c", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The EU DAC8 regime regulates the reporting and exchange of tax information regarding crypto-asset users (c0300673081f7232::320::7b46, c0300673081f7232::498::163c). The INT_BASEL_CRYPTO regime regulates capital requirements, risk-weighting, and supervisory standards for banks and financial institutions (32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). The obligations in DAC8 relate to tax transparency and administrative cooperation, while the obligations in INT_BASEL_CRYPTO relate to prudential regulation and capital adequacy. There is no specific obligation in one regime that pushes against a specific obligation in the other; they regulate distinct domains of financial activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:2e36829aa3120300d560ab19", "label": "conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "AU_AML_CTF (Australian AML/CTF Act — AUSTRAC reporting framework requiring KYC, threshold, and suspicious-matter reporting) and SG_PDPA (Singapore Personal Data Protection Act). When AU reporting entities have SG-resident customers and need to share data per AML/CTF obligations, PDPA's consent/disclosure restrictions engage on the SG side. Operationally resolvable via PDPA s.13(b) ('required or authorised under any other written law') carve-out for AML compliance. Same conflict shape as the labelled AU AML/CTF ↔ AU PRIVACY conflict, scaled to cross-jurisdictional framing.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:52Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:45:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:d6eb635a42e7ac6fd1e9c086", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::340::9399", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 21, "passage": "1. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n2. MiCA sets out a new legal framework applicable to legal persons or other undertakings\nintending to provide crypto-asset services, requiring such entities to submit an\napplication for authorisation containing all the information set out in Article 62(2) of MiCA,\nas specified by the RTS on the information for authorisation as a CASP.\n\n3. The next paragraphs present the cost-benefit analysis of the main policy options included\nin this final report on the requirements for the application for authorisation as a CASP\nunder Article 62 of MiCA.\nProblem identification"}], "rationale": "The evidence for AU_PRIVACY focuses on the obligations of an Australian entity to ensure overseas recipients of personal information comply with Australian Privacy Principles (APPs) and the accountability for such disclosures. The evidence for EU_MICA_TITLE_V_CASP focuses on the requirements for legal entities to apply for authorisation as a Crypto-Asset Service Provider (CASP) under the Markets in Crypto-Assets (MiCA) Regulation, including the information required for the application and the establishment of a public register. The obligations in the AU_PRIVACY passage (ensuring overseas recipients handle personal information in accordance with APPs) do not directly oppose the obligations in the EU_MICA passage (submitting an application for authorisation as a CASP). The regimes regulate different aspects of the same transaction or entity: one governs data protection and cross-border data flows, while the other governs the licensing and operational requirements for providing crypto-asset services. Therefore, the regimes are in different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:55:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:4fc902204564365498519327", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "rationale": "The AU_TRAVEL_RULE passages discuss Australia's regulatory framework for digital currency exchanges (DCEs) and the status of the FATF 'Travel Rule' implementation. Specifically, they state that Australia has not yet implemented the Travel Rule for digital currency exchanges and is consulting on reforms to extend it (chunk_ids cf7cefacba3f94bc::383::7d9d, 30a32a386d15ba2b::4f3::edc3). The EU_NIS2 passages discuss the Network and Information Security Directive (NIS2) and its technical standards for access controls in the context of ICT security (chunk_id 3c9eb3a25c93f394::474::4786). The obligations in AU_TRAVEL_RULE relate to customer identification and transaction reporting (Travel Rule), while the obligations in EU_NIS2 relate to cybersecurity and access control policies. These are distinct regulatory domains. Furthermore, the AU passages explicitly state that the Travel Rule is not yet implemented, meaning the specific obligations referenced in the AU regime are not currently active, while the EU regime addresses a different set of obligations entirely. Therefore, the regimes do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:357607806087e88fd31e85ca", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "75b61beed88910f9::4ad::debc", "source_doc": "National_ML_TF_Risk_Assessment.pdf.coredownload.inline.pdf", "page": null, "passage": "The guidance contained in this document takes into consideration previous FATF work , which is still valid reference material. The general\nprinciples contained in this paper are also relevant when conducting risk assessments of a more\nfocussed scope, such as in assessments of a particular financial or DNFBP sector (for example, the\nsecurities sector) or of thematic issues (for example, the proceeds of corruption related ML). All of\nthese types of assessments (comprehensive, sectoral or thematic) carried out at the national level\nmay also form the basis for determining whether to apply enhanced or specific measures, simplified\nmeasures, or exemptions from AML/CFT requirements. Furthermore, while FATF\nRecommendation 1 does not create specific risk assessment obligations regarding the financing of\nproliferation of weapons of mass destruction, the general principles laid out in this guidance could\nalso be used in conducting a risk assessment for this area.\n3. The guidance in this document is not intended to explain how supervisors should assess risks\nin the context of risk-based supervision, although risk-based supervision will likely be informed by a\nnational-level risk assessment."}], "evidence_b": [{"chunk_id": "6d8a84a9f3d6e9e4::480::ac46", "source_doc": "Guidelines_to_MAS_Notice_SFA04-N02_2025.pdf", "page": 5, "passage": "2 The FSM Sanctions Regulations include the regulations issued under section 192 read with sections 15(1)(b) and 219(d)\nof the FSM Act. Please refer to the following link for the FSM Sanctions Regulations:\nhttps://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions/regulations-for-targeted-financial-\nsanctions. Currently, the relevant FSM Sanctions Regulations are those relating to the Democratic People's Republic of\nKorea and Iran. concerns. Other support functions such as operations, human resource or\ntechnology also play a role to help mitigate the ML/TF risks that the CMI faces. The AML/CFT compliance function is typically the contact point regarding all\nAML/CFT issues for domestic and foreign authorities, including supervisory\nauthorities, law enforcement authorities and financial intelligence units.\n1-4-14 As the third line of defence, the CMI's internal audit function or an equivalent\nfunction plays an important role in independently evaluating the AML/CFT risk\nmanagement framework and controls for purposes of reporting to the audit\ncommittee of the CMI's board of directors, or a similar oversight body."}, {"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "INT_FATF_GENERAL (FATF's general AML/CFT risk-assessment principles and standards) and SG_MAS_AML_GENERAL (MAS's AML/CFT framework — FSM Act sanctions regulations, MAS PSN02 supervisory approach). Singapore implements FATF risk-based AML/CFT principles through MAS notices and guidelines. Reinforcing relationship."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:39:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:95c8e92128e4484a523cc2ab", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "rationale": "The AU_TTR_THRESHOLD regime regulates the reporting of physical currency transfers exceeding A$10,000 to AUSTRAC. The EU_REVERSE_SOLICITATION regime regulates the marketing of crypto-asset services to clients in the EU who have initiated the relationship. The obligations in Regime A (reporting cash thresholds) do not overlap with the obligations in Regime B (reverse solicitation exemptions for crypto-asset services). The regimes regulate distinct transaction types and compliance areas, resulting in no conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:24:18Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:8db7ec34d0df55a3b80a28f6", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "evidence_b": [{"chunk_id": "6d8a84a9f3d6e9e4::480::ac46", "source_doc": "Guidelines_to_MAS_Notice_SFA04-N02_2025.pdf", "page": 5, "passage": "2 The FSM Sanctions Regulations include the regulations issued under section 192 read with sections 15(1)(b) and 219(d)\nof the FSM Act. Please refer to the following link for the FSM Sanctions Regulations:\nhttps://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions/regulations-for-targeted-financial-\nsanctions. Currently, the relevant FSM Sanctions Regulations are those relating to the Democratic People's Republic of\nKorea and Iran. concerns. Other support functions such as operations, human resource or\ntechnology also play a role to help mitigate the ML/TF risks that the CMI faces. The AML/CFT compliance function is typically the contact point regarding all\nAML/CFT issues for domestic and foreign authorities, including supervisory\nauthorities, law enforcement authorities and financial intelligence units.\n1-4-14 As the third line of defence, the CMI's internal audit function or an equivalent\nfunction plays an important role in independently evaluating the AML/CFT risk\nmanagement framework and controls for purposes of reporting to the audit\ncommittee of the CMI's board of directors, or a similar oversight body."}, {"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "The EU_EMD2 passages discuss digital operational resilience and financial rules for the Authority (chunk_ids cf4bab4773787409::1e6::5413 and 3a1785f95cb37b3c::34d::1756). The SG_MAS_AML_GENERAL passages discuss AML/CFT compliance, sanctions regulations, and cybersecurity issues related to money laundering (chunk_ids 6d8a84a9f3d6e9e4::480::ac46 and b49627bb889ef1d9::1b6::0802). The obligations in the EU regime regarding digital resilience do not impose specific requirements that conflict with the Singapore AML/CFT obligations regarding sanctions and cybersecurity. The regimes regulate distinct but related aspects of financial sector oversight (operational resilience vs. AML/CFT compliance), resulting in no direct conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:07:40Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:0ca9547c8a503b9418331218", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}, {"chunk_id": "39886a6842407c92::356::ee53", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 6, "passage": "3.1 This Notice is based on the following principles, which shall serve as a guide for all banks\nin the conduct of their operations and business activities:\n(a) A bank shall exercise due diligence when dealing with customers, natural persons\nappointed to act on the customer's behalf, connected parties of the customer and\nbeneficial owners of the customer.\n(b) A bank shall conduct its business in conformity with high ethical standards, and\nguard against establishing any business relations or undertaking any transaction,\nincluding a digital token transaction, that is or may be connected with, or facilitates\nor may facilitate money laundering or terrorism financing.\n(c) A bank shall, to the fullest extent possible, assist and cooperate with the relevant\nlaw enforcement authorities in Singapore to prevent money laundering and\nterrorism financing."}], "rationale": "The EU_EMD2 passages discuss digital operational resilience and financial rules for the European Authority (e.g., Recital 27, Article 21). The SG_AML passages discuss AML/CFT training obligations for insurers (Clause 13.14) and general AML/CFT principles for banks (Clause 3.1). The obligations in the EU_EMD2 text relate to operational resilience and financial administration, whereas the obligations in the SG_AML text relate to anti-money laundering and counter-terrorism financing controls. These are distinct regulatory domains with no apparent overlap or conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:38:00Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:d1841a6481b4324076bf4a63", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "The evidence from AU_TREASURY_DAP (chunk d75262e404517e0c::47b::7c9f) describes Australia's internal 'token mapping' exercise to identify how crypto assets fit into existing financial services laws. The evidence from SG_MAS_PRUDENTIAL_CRYPTO (chunk 7c04f2a0bd85290a::449::02f2) discusses Singapore's specific regulatory framework for Stablecoin Issuers (SCS) and their capital requirements. The two regimes are addressing distinct policy objectives and regulatory designs for different jurisdictions (Australia's mapping exercise vs. Singapore's SCS prudential framework). There is no specific obligation in one regime that pushes against a specific obligation in the other; rather, they represent separate national approaches to crypto regulation."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:52:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:46bda7555d6b5344ea0ca714", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}], "rationale": "The AU_TREASURY_DAP passages discuss the Australian government's internal policy agenda, specifically 'token mapping' to identify how crypto assets fit into existing financial services laws and the subsequent development of a licensing framework for crypto asset service providers (chunks d75262e404517e0c::47b::7c9f, e6bb47e92e88e16c::37a::29f6). In contrast, the EU_MAR passages define the scope of the Market Abuse Regulation, which establishes rules on insider dealing and market manipulation for financial instruments in the EU (chunk 5cc4a27bc578287a::165::3333). The two regimes regulate distinct policy areas: one is a domestic regulatory reform agenda for crypto assets, while the other is a specific EU directive prohibiting market abuse. There is no evidence of a direct obligation in one regime conflicting with a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.86, "record_type": "non_conflict", "pair_id": "non_conflict:fd156bf7aa19604a8f0821b3", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AML/CTF Act + Rules"}, "regime_b": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 234 Information Security"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d38ec0ddcc912963::450::6872", "source_doc": "Reporting.pdf", "page": null, "passage": "'@ Australian Government Cee ee\nahem 8 eporting Home / Business / Core guidance / Reporting As a reporting entity you must report certain transactions and suspicious matters, and\nsubmit compliance reports to AUSTRAC. Everyone, including reporting entities, must\nreport cross-border movements of physical currency. Ongoing reporting obligations Threshold transaction reports You must submit threshold transaction reports (TTR) for transfers of A$10,000 or more\nin cash (or the foreign currency equivalent). TTRs are due within 10 business days after\nthe date of the transaction. International funds transfer instruction reports (IFTIs) You must submit international funds transfer instruction reports (IFTIs) for transfers of\nfunds of any value into or out of Australia, made either electronically or under a\ndesignated remittance arrangement. IFTIs are due within 10 business days after the\ntransfer instruction is sent or received. Suspicious matter reports (SMRs) You must submit suspicious matter reports (SMRs) when you have a suspicion that a\ncustomer or transaction is related to criminal activity."}, {"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}], "evidence_b": [{"chunk_id": "ddcef7b1f5780c26::5d3::163e", "source_doc": "CPS_234_Information_Security.pdf", "page": null, "passage": "Prudential Standard CPS 234\nInformation Security\nObjectives and key requirements of this Prudential\nStandard\nThis Prudential Standard aims to ensure that an APRA-regulated entity takes\nmeasures to be resilient against information security incidents (including cyber-\nattacks) by maintaining an information security capability commensurate with\ninformation security vulnerabilities and threats.\nA key objective is to minimise the likelihood and impact of information security\nincidents on the confidentiality, integrity or availability of information assets,\nincluding information assets managed by related parties or third parties.\nThe Board of an APRA-regulated entity is ultimately responsible for ensuring that\nthe entity maintains its information security.\nThe key requirements of this Prudential Standard are that an APRA-regulated entity\nmust:\n clearly define the information security-related roles and responsibilities of the\nBoard, senior management, governing bodies and individuals;\n maintain an information security capability commensurate with the size and\nextent of threats to its information assets, and which enables the continued\nsound operation of the entity;\n implement controls to protect its information assets commensurate with the\ncriticality and sensitivity of those information assets, and undertake\nsystematic testing and assurance regarding the effectiveness of those controls;\nand\n notify APRA of material information security incidents.\nCPS 234 - 1\n\nAuthority"}, {"chunk_id": "ddcef7b1f5780c26::349::3a27", "source_doc": "CPS_234_Information_Security.pdf", "page": 7, "passage": "32. An APRA-regulated entity's internal audit activities must include a review of the\ndesign and operating effectiveness of information security controls, including\n\n11 Also referred to as an 'untrusted' environment.\n\n12 For the avoidance of doubt, paragraph 28 of this Prudential Standard applies to all information\nassets managed by related parties and third parties, not only those captured under agreements with\nservice providers of outsourced material business activities under Prudential Standard CPS 231\nOutsourcing or Prudential Standard SPS 231 Outsourcing.\nCPS 234 - 7\n\nthose maintained by related parties and third parties (information security control\nassurance).\n\n33. An APRA-regulated entity must ensure that the information security control\nassurance is provided by personnel appropriately skilled in providing such\nassurance."}], "rationale": "The AML/CTF Act and Rules regulate customer due diligence, transaction monitoring, threshold transaction reporting and suspicious matter reporting; CPS 234 is APRA's prudential information-security standard. They apply to overlapping but not identical populations (APRA-regulated entities that are also reporting entities under AML/CTF — banks, super funds, life insurers, etc.) and they govern entirely different obligation surfaces: AML/CFT controls vs ICT-security capability. A regulated firm satisfies both with independent controls; the only point of practical interaction is incident notification where an ICT incident also has AML/CFT implications, and that is a routine coordination matter.", "would_conflict_if": ["AUSTRAC required retention of records on systems CPS 234 would require to be air-gapped from external access — no such tension in current text."]}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:50:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.7, "record_type": "conflict", "pair_id": "conflict:05f82391f7652f5579a1f248", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "GDPR"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "Market Abuse Regulation"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::4a6::7573", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 1, "passage": "Consistent and\nhomogenous application of the rules for the protection of the fundamental rights and freedoms of natural\npersons with regard to the processing of personal data should be ensured throughout the Union. Regarding the\nprocessing of personal data for compliance with a legal obligation, for the performance of a task carried out in\nthe public interest or in the exercise of official authority vested in the controller, Member States should be\nallowed to maintain or introduce national provisions to further specify the application of the rules of this\nRegulation. In conjunction with the general and horizontal law on data protection implementing Directive\n95/46/EC, Member States have several sector-specific laws in areas that need more specific provisions. This\nRegulation also provides a margin of manoeuvre for Member States to specify its rules, including for the\nprocessing of special categories of personal data ('sensitive data'). To that extent, this Regulation does not exclude\nMember State law that sets out the circumstances for specific processing situations, including determining more\nprecisely the conditions under which the processing of personal data is lawful."}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "bd84e63f5b622b73::2ad::e920", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 64, "passage": "Article 48\nTransfers or disclosures not authorised by Union law\nAny judgment of a court or tribunal and any decision of an administrative authority of a third country requiring a\ncontroller or processor to transfer or disclose personal data may only be recognised or enforceable in any manner if\nbased on an international agreement, such as a mutual legal assistance treaty, in force between the requesting third\ncountry and the Union or a Member State, without prejudice to other grounds for transfer pursuant to this Chapter.\n\nArticle 49\nDerogations for specific situations\n1. In the absence of an adequacy decision pursuant to Article 45(3), or of appropriate safeguards pursuant to"}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::4ec::f8d9", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 47, "passage": "Article 29\nDisclosure of personal data to third countries\n1. The competent authority of a Member State may transfer personal data to a third country provided the\nrequirements of Directive 95/46/EC are fulfilled and only on a case-by-case basis. The competent authority shall\nensure that the transfer is necessary for the purpose of this Regulation and that the third country does not transfer\nthe data to another third country unless it is given express written authorisation and complies with the conditions\nspecified by the competent authority of the Member State.\n2. The competent authority of a Member State shall only disclose personal data received from a competent authority\nof another Member State to a supervisory authority of a third country where the competent authority of the Member\nState concerned has obtained express agreement from the competent authority which transmitted the data and, where\napplicable, the data is disclosed solely for the purposes for which that competent authority gave its agreement.\n3. Where a cooperation agreement provides for the exchange of personal data, it shall comply with the national laws,\nregulations or administrative provisions transposing Directive 95/46/EC.\nCHAPTER 5\nADMINISTRATIVE MEASURES AND SANCTIONS"}, {"chunk_id": "5cc4a27bc578287a::1bd::d04c", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 14\nProhibition of insider dealing and of unlawful disclosure of inside information\nA person shall not:\n(a) engage or attempt to engage in insider dealing;\n(b) recommend that another person engage in insider dealing or induce another person to engage in insider dealing; or\n(c) unlawfully disclose inside information.\n\nArticle 15\nProhibition of market manipulation\nA person shall not engage in or attempt to engage in market manipulation."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "rationale": "MAR Article 29 expressly contemplates that competent authorities may transfer personal data to third countries — subject to (former) Directive 95/46/EC requirements, now GDPR. MAR Article 16 STOR (suspicious transaction or order report) and insider-list maintenance under Article 18 involve substantial personal-data processing. GDPR Articles 5-6 require purpose limitation and lawful basis; Article 44 regulates cross-border transfers; Article 48 forecloses third-country court/administrative orders not based on international agreement. The tension is operational: MAR requires personal-data processing for market-abuse supervision and cross-border information sharing; GDPR demands the standard lawful-basis ladder and transfer-instrument framework. Resolution: GDPR Art 6(1)(c) (legal obligation, namely MAR) is the lawful basis; for cross-border transfer, MAR Article 29's own framework supplements GDPR Chapter V; for non-EU regulator cooperation, MOU-based arrangements satisfy GDPR Art 46(2)(a) administrative arrangements between public authorities.", "compliant_paths": ["Use GDPR Art 6(1)(c) (legal obligation = MAR) for STOR / insider-list / supervisory data processing.", "For cross-border supervisory transfer, layer MAR Art 29's specific framework on top of GDPR Chapter V; MOUs satisfy Art 46(2)(a).", "Ensure GDPR Art 48 is not violated when cooperating with non-EU subpoenas — require an international agreement basis."], "out_of_scope_assumptions": ["EU competent authority or in-scope market participant; non-financial-instrument data is outside MAR scope."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:31:56Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:8cf39583224bcf39fd9a2d66", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "rationale": "The evidence from Regime A (AU_FEDREG_AML) focuses on Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations, specifically regarding reporting entities, customer identification, and suspicious transaction reporting. The evidence from Regime B (INT_BASEL_GENERAL) focuses on banking regulatory capital, leverage ratios, and the treatment of fiduciary assets and provisions. The obligations and subject matter are distinct; there is no specific obligation in the AML/CTF regime that pushes against a specific obligation in the Basel framework. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:b2b34adea2553f5719a21b45", "label": "non_conflict", "regime_a": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}, {"chunk_id": "33d059aa86716ddd::4ed::8511", "source_doc": "2022_CP_Stablecoin_Regulatory_Approach.pdf", "page": 6, "passage": "3.5 A wide range of stablecoins currently exist, varying in terms of their asset-\npegging, as well as the mechanism that upholds the stability of the stablecoins' value\nagainst the pegged asset(s). MAS intends to focus its regulatory regime on:\nSingle-currency pegged stablecoins (SCS) - As compared to other types of\nstablecoins (such as those pegged to a basket of currencies or other\nassets such as commodities), SCS has a stronger use case for payment and\nsettlement.\nNon-SCS will continue to be subject to the existing DPT regime under the\nPS Act. MAS views such stablecoins as being less stable in nominal value\nand should be treated differently from SCS.\nIn addition, even among SCS, there is variation in the stabilisation\nmechanism. MAS views stablecoins which are algorithmically-pegged,\nunbacked or backed by other cryptocurrencies to be more susceptible to\nvolatility in value. Correspondingly, such stablecoins will also continue to\nbe treated as DPTs.\nSCS issued in Singapore - The immediate priority of MAS is to elevate the\nstandard of SCS issued in Singapore. Our regulatory perimeter is thus\nscoped based on MAS' ability to directly impose requirements on the\nreserve management, redemption policies and prudential standards of\nthe SCS issuer."}], "rationale": "SG_MAS_AML_GENERAL (MAS AML/CFT supervisory framework for DPT providers) and SG_STABLECOIN (MAS's SCS regulatory framework for stablecoin issuers). Both are MAS-issued frameworks for crypto/digital-payment-token activities in Singapore; they apply in tandem (an SCS issuer that is also a DPT-service provider faces both). Reinforcing rather than conflicting — both arms of MAS's coordinated crypto regulatory architecture."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:1e81f53db57979283456197a", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "75b61beed88910f9::4ad::debc", "source_doc": "National_ML_TF_Risk_Assessment.pdf.coredownload.inline.pdf", "page": null, "passage": "The guidance contained in this document takes into consideration previous FATF work , which is still valid reference material. The general\nprinciples contained in this paper are also relevant when conducting risk assessments of a more\nfocussed scope, such as in assessments of a particular financial or DNFBP sector (for example, the\nsecurities sector) or of thematic issues (for example, the proceeds of corruption related ML). All of\nthese types of assessments (comprehensive, sectoral or thematic) carried out at the national level\nmay also form the basis for determining whether to apply enhanced or specific measures, simplified\nmeasures, or exemptions from AML/CFT requirements. Furthermore, while FATF\nRecommendation 1 does not create specific risk assessment obligations regarding the financing of\nproliferation of weapons of mass destruction, the general principles laid out in this guidance could\nalso be used in conducting a risk assessment for this area.\n3. The guidance in this document is not intended to explain how supervisors should assess risks\nin the context of risk-based supervision, although risk-based supervision will likely be informed by a\nnational-level risk assessment."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "INT_FATF_GENERAL (FATF AML/CFT general standards and risk-based approach) and INT_IOSCO_GENERAL (IOSCO securities-regulation principles). Both are international standards bodies addressing financial regulation from different angles (AML and securities regulation); they coordinate on overlapping issues like crypto-related concerns. Aligned pillars of international financial regulation."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:50:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:a8d15610863d06b15cce3e04", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::4f2::95d6", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Such a warning may be\nprovided in a standardised format;\n(d) the investment firm complies with its obligations under Article 23.\n5. The investment firm shall establish a record that includes the document or documents agreed between the\ninvestment firm and the client that set out the rights and obligations of the parties, and the other terms on which\nthe investment firm will provide services to the client. The rights and duties of the parties to the contract may be\nincorporated by reference to other documents or legal texts.\n6. The investment firm shall provide the client with adequate reports on the service provided in a durable medium. Those reports shall include periodic communications to clients, taking into account the type and the complexity of\nfinancial instruments involved and the nature of the service provided to the client and shall include, where applicable, the\ncosts associated with the transactions and services undertaken on behalf of the client. When providing investment advice, the investment firm shall, before the transaction is made, provide the client with a\nstatement on suitability in a durable medium specifying the advice given and how that advice meets the preferences,\nobjectives and other characteristics of the retail client."}, {"chunk_id": "28dfda0f6a6539b6::514::0ca0", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 57, "passage": "Article 24\nGeneral principles and information to clients\n1. Member States shall require that, when providing investment services or, where appropriate, ancillary services to\nclients, an investment firm act honestly, fairly and professionally in accordance with the best interests of its clients and\ncomply, in particular, with the principles set out in this Article and in Article 25.\n2. Investment firms which manufacture financial instruments for sale to clients shall ensure that those financial\ninstruments are designed to meet the needs of an identified target market of end clients within the relevant category\nof clients, the strategy for distribution of the financial instruments is compatible with the identified target market, and the\ninvestment firm takes reasonable steps to ensure that the financial instrument is distributed to the identified target\nmarket. An investment firm shall understand the financial instruments they offer or recommend, assess the compatibility of the\nfinancial instruments with the needs of the clients to whom it provides investment services, also taking account of the\nidentified target market of end clients as referred to in Article 16(3), and ensure that financial instruments are offered or\nrecommended only when this is in the interest of the client.\n3."}], "rationale": "The AU_PRIVACY passages (e9f6b0a9e797777d::5d6::e5ff, e9f6b0a9e797777d::4ba::1af3) regulate the cross-border transfer of personal information, requiring entities to ensure overseas recipients comply with Australian Privacy Principles. The EU_MIFID2 passages (28dfda0f6a6539b6::4f2::95d6, 28dfda0f6a6539b6::514::0ca0) regulate the conduct of investment firms, focusing on client suitability, information disclosure, and record-keeping. The obligations in MIFID2 relate to financial services conduct and client communication, whereas the obligations in APP 8 relate to data protection and privacy. There is no specific obligation in MIFID2 that pushes against a specific obligation in APP 8; they regulate distinct domains of financial services regulation and data protection."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:f07b67334e865f298de77974", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "regime_b": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DAC 8 (crypto tax)"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3a1785f95cb37b3c::336::8d0b", "source_doc": "AMLA_Regulation_EU_2024-1620.pdf", "page": 32, "passage": "The list of\nthe selected obliged entities shall be published by the Authority without undue delay upon completion of the selection\nprocess. The Authority shall commence direct supervision of the selected obliged entities six months after publication of\nthe list.\n5. Prior to the publication of the list of the selected obliged entities, the Authority shall inform the relevant\nnon-AML/CFT authorities of the outcomes of the process of assessment and classification of inherent and residual risk of\nthe obliged entities subject to assessment.\n6. A selected obliged entity shall remain subject to direct supervision by the Authority until the Authority commences\nthe direct supervision of selected obliged entities based on a list established for the subsequent selection period which no\nlonger includes that obliged entity."}], "evidence_b": [{"chunk_id": "c0300673081f7232::4d9::6684", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 25, "passage": "B. Due diligence procedures for Entity Crypto-Asset Users\nThe following procedures apply for the purpose of determining whether the Entity Crypto-Asset User is a Reportable\nUser or an Entity, other than an Excluded Person or an Active Entity, with one or more Controlling Persons who are\nReportable Persons.\n1. Determine whether the Entity Crypto-Asset User is a Reportable Person. (a) When establishing the relationship with the Entity Crypto-Asset User, or with respect to Pre-existing Entity\nCrypto-Assets Users by 1 January 2027, the Reporting Crypto-Asset Service Provider shall obtain a self-\ncertification that allows the Reporting Crypto-Asset Service Provider to determine the Entity Crypto-Asset\nUser's residence(s) for tax purposes and confirm the reasonableness of such self-certification based on the\ninformation obtained by the Reporting Crypto-Asset Service Provider, including any documentation collected\npursuant to Customer Due Diligence Procedures. If the Entity Crypto-Asset User certifies that it has no\nresidence for tax purposes, the Reporting Crypto-Asset Service Provider may rely on the place of effective\nmanagement or the address of the principal office to determine the residence of the Entity Crypto-Asset User."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLA Regulation establishing the AML supervisor and EU DAC 8 crypto-asset tax-reporting directive operate in disjoint regulatory domains at the obligation level. AMLA supervises AML obliged entities; DAC8 is a tax-reporting directive — disjoint regulatory purposes. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:38:50Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:8afc8f8b363f6af087cff727", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::15a::fbf2", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 80, "passage": "Article 63\nCooperation with AMLA\nFIU and supervisory authorities shall cooperate with AMLA and shall provide it with all the information necessary to allow\nit to carry out its duties under this Directive and under Regulations (EU) 2024/1624 and (EU) 2024/1620.\nSECTION 2\nCooperation with other authorities and exchange of confidential information"}, {"chunk_id": "df546f2364aaf9e2::620::328c", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 79, "passage": "Article 62\nCommunication of the list of the competent authorities\n1. In order to facilitate and promote effective cooperation, and in particular the exchange of information, Member States\nshall communicate to the Commission and AMLA:\n(a) the list of supervisors responsible for overseeing the compliance of the obliged entities with Regulation (EU)\n2024/1624, as well as, where relevant, name of the public authority overseeing self-regulatory bodies in their\nperformance of supervisory functions under this Directive, and their contact details;\n(b) the contact details of their FIU;\n(c) the list of other competent national authorities.\n2. For the purposes of paragraph 1, the following contact details shall be provided:\n(a) a contact point or, failing that, the name and role of a contact person;\n(b) the email and phone number of the contact point or, failing that, the professional email address and phone number of\nthe contact person.\nELI: http://data.europa.eu/eli/dir/2024/1640/oj 79/94\n\nEN\n3. Member States shall ensure that the information provided to the Commission and AMLA pursuant to paragraph 1 is\nupdated as soon as a change takes place.\n4. AMLA shall publish a register of the authorities referred to in paragraph 1 on its website and facilitate the exchange of\ninformation referred to in paragraph 2 between competent authorities. The authorities in the register shall, within the scope\nof their powers, serve as a contact point for the counterpart competent authorities. FIUs and supervisory authorities shall\nalso serve as a contact point for AMLA."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::25d::6825", "source_doc": "d424.pdf", "page": 85, "passage": "150. At national supervisory discretion, banks using both the standardised and IRB approaches may\nrely on their internal methods for allocating general provisions for recognition in capital under either the\nstandardised or IRB approach, subject to the following conditions. Where the internal allocation method\nBasel III: Finalising post-crisis reforms 81\n\nis made available, the national supervisor will establish the standards surrounding their use. Banks will\nneed to obtain prior approval from their supervisors to use an internal allocation method for this purpose.\n\n3. Treatment of EL and provisions"}], "rationale": "The EU AMLA passages (chunk_ids df546f2364aaf9e2::15a::fbf2 and df546f2364aaf9e2::620::328c) regulate cooperation obligations, information exchange, and the establishment of an AML authority. The INT_BASEL_GENERAL passages (chunk_ids 32afd37cade34f84::34b::8d30 and 32afd37cade34f84::25d::6825) regulate banking capital adequacy, specifically the leverage ratio and the treatment of general provisions. The obligations in the EU AMLA framework do not impose requirements on banking capital ratios or leverage exposure measures, nor do they conflict with the Basel III capital treatment rules. Therefore, the regimes regulate distinct domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:15:44Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.72, "record_type": "conflict", "pair_id": "conflict:c1f247f99d7b062b4f39ca12", "label": "conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "550958b067dc6726::41f::546c", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 24, "passage": "3.1 Standard AFSL Obligations\nAustralian financial services licence\n(a) A platform provider must hold an AFSL authorising them to issue and deal in digital asset facilities.\n(b) A platform provider is exempt from holding an AFSL for digital asset facilities if:\n(i) the total value of platform entitlements held by any one client of the platform provider does\nnot exceed $1,500 at any one time; and\n(ii) the total amount of assets held by the platform provider does not exceed $5 million at any\ntime.\nInfo Box 3 Low value exemption\nThe risks with digital asset facilities are correlated to the size and scale of the asset holding role of\nthe platform provider. Accordingly, a 'low-value facility' exemption would be introduced, similar to\nthe 'low value facility' exemption for non-cash payment facilities. It would apply to digital asset\nfacilities holding less than $1,500 per customer and less than $5 million in total.40 This exemption\nis intended to allow for innovation and experimentation in the early stages of developing a novel\nservice offering."}, {"chunk_id": "550958b067dc6726::74a::7ef1", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 26, "passage": "46 For information on ASIC's interpretation of this obligation, see ASIC PF 209 Australian financial services\nlicence conditions\nLicensing digital asset intermediaries | 23\n\n(vi) having the financial,47 technological, and human resources to carry out and supervise the\nfinancial service covered by the AFSL,\n(vii) having a dispute resolution system48 and compensation arrangements for retail clients for\nloss or damage suffered due to breaches of obligations, and\n(viii) maintaining a risk management system.\nFinancial requirements\n(g) A platform provider must meet:\n(i) the standard solvency and positive net asset requirements,49\n(ii) the standard cash needs requirement, and\n(iii) a net tangible assets (NTA) requirement for holding cash or cash equivalents and holding\nliquid assets of at least:\n• 0.5 per cent of the value of the facility (if using a sub-custodian digital asset facility that\nhas $5m NTA),50 or\n• $5 million (if performing the custody function).\nInfo Box 6 Financial requirements\nAFSL holders have obligations to meet 'financial requirements'. These requirements are typically\ntailored for different financial products through ASIC legislative instruments. The NTA obligation is\nto address the costs of orderly wind-up in the event the provider fails.51\nA key issue with digital assets is concentration risk (see Info Box 11 Additional Standards for token\nholders). The proposed financial requirements balance the need to avoid concentration of digital\nassets among a small number of custodians with the need to ensure robust NTA. It sets the\nrequired level of NTA at the greater of $5 million or 0.5% of the value of the assets held by the\nfacility.52 This arrangement ensures that as a facility expands, and the operational risk exposure of\nthe platform provider grows, the provider will maintain a corresponding level of financial\nresources."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}, {"chunk_id": "0e996ae99839f19e::3d0::2bb3", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "2020Ed. Act 2012 20\n(2) An organisation must not -\n(a) as a condition of providing a product or service, require an\nindividual to consent to the collection, use or disclosure of\npersonal data about the individual beyond what is\nreasonable to provide the product or service to that\nindividual; or\n(b) obtain or attempt to obtain consent for collecting, using or\ndisclosing personal data by providing false or misleading\ninformationwithrespecttothecollection,useordisclosure\nof the personal data, or using deceptive or misleading\npractices. (3) Anyconsentgiveninanyofthecircumstancesinsubsection(2)\nis not validly given for the purposes of this Act. (4) InthisAct,referencestoconsentgiven,ordeemedtohavebeen\ngiven, by an individual for the collection, use or disclosure of\npersonal data about the individual include consent given, or deemed\nto have been given, by any person validly acting on that individual's\nbehalf for the collection, use or disclosure of such personal data."}], "rationale": "AU_ASIC_AFSL (AFSL holders' KYC, suitability, and recordkeeping obligations under s.912A of the Corporations Act and ASIC INFO 225 for crypto-asset facilities) and SG_PDPA (Singapore PDPA consent-based collection/disclosure). AFSL licensees serving SG-resident clients must collect and retain client-identification data and may transmit it to SG counterparties for AML/CDD; PDPA restricts the SG-side collection/disclosure absent the 'required by law' carve-out. Operationally resolvable via PDPA s.13(b) + MAS AML framework providing the SG-side statutory authorisation. Lower severity than the AML conflicts because AFSL KYC is contractually based (Art. 6(1)(b)-style lawful basis available).", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:24Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:34a49a548c4612b73add63d5", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "AU_FEDREG_AML (Australian AML/CTF Act and Rules — AUSTRAC reporting framework) and SG_AML (MAS Notice 314 AML/CFT framework for life insurers). Both jurisdictions implement comparable AML/CFT obligations consistent with FATF standards. Reinforcing."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:51a8e72e85ebd3c6b4499466", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 230"}, "regime_b": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU TTR Threshold"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): APRA CPS 230 operational-risk management standard and AUSTRAC TTR $10k cash threshold reporting operate in disjoint regulatory domains at the obligation level. Operational risk vs AML threshold reporting — disjoint subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:16:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:02b87845d13eacf52fa1e6e2", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "rationale": "The obligations in Prudential Standard CPS 230 (Regime A) focus on operational risk management, business continuity, and the resilience of critical operations for APRA-regulated entities (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c). In contrast, the obligations in Regulation (EU) 2023/1114 (Regime B) address the content and liability of crypto-asset white papers for issuers of e-money tokens (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e). The two regimes regulate distinct aspects of financial services—operational resilience versus disclosure and liability for token issuers—and do not impose conflicting obligations on the same activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:25:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:ac566738a684d56a48cdc648", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d7502c011527b67c::3e7::ae26", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 13, "passage": "This Regulation shall not apply to a transfer of funds where any of the following conditions is met:\n(a) it involves the payer withdrawing cash from the payer's own payment account;\n(b) it constitutes a transfer of funds to a public authority as payment for taxes, fines or other levies within a Member\nState;\n(c) both the payer and the payee are payment service providers acting on their own behalf;\n(d) it is carried out through cheque images exchanges, including truncated cheques. This Regulation shall not apply to a transfer of crypto-assets where any of the following conditions is met:\n(a) both the originator and the beneficiary are crypto-asset service providers acting on their own behalf;\n(b) the transfer constitutes a person-to-person transfer of crypto-assets carried out without the involvement of a crypto-\nasset service provider. Electronic money tokens, as defined in Article 3(1), point (7), of Regulation (EU) 2023/1114, shall be treated as crypto-\nassets under this Regulation."}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}], "rationale": "The EU AMLR TFR passage (c7502c011527b67c::3e7::ae26) establishes an exemption for transfers of funds to public authorities for taxes, fines, or levies. The SG IRAS TFR passage (abc2247bc6415d1d::41e::b184) confirms that digital payment tokens are exempt from GST. These obligations operate in different domains: one regulates the information accompanying transfers to prevent money laundering, while the other regulates the tax treatment of the tokens themselves. There is no specific obligation in the EU regime that conflicts with the SG tax treatment of digital payment tokens."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:96e13b0dc974f5b7abf99cff", "label": "conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "EU_AMLR_TFR (EU regulation extending AML/CFT to CASPs and mandating information accompanying crypto-asset transfers — Regulation 2023/1113 with originator/beneficiary personal-data sharing requirements) and SG_PDPA (Singapore PDPA restricting collection, use and disclosure of personal data without consent or statutory authorisation). When EU CASPs send crypto value to SG counterparties, the TFR's mandated personal-data disclosure engages PDPA's restrictions on the SG side. Operationally resolvable via PDPA s.13(b) ('required or authorised under any other written law') in combination with MAS's AML/CFT notice framework establishing the SG-side legal basis. Same conflict shape as the labelled EU TFR ↔ EU GDPR conflict in the careful cohort, scaled to the SG-cross-jurisdiction framing.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:14Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:40:06Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:b441be62c50674b2120a3baf", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "0fc4f857c226f510::375::66b5", "source_doc": "Corporations_Act_2001_Vol1.pdf", "page": 296, "passage": "Part 1.6 Interaction with Australian Charities and Not-for-profits Commission Act Section 111L\nProvisions of this Act that do not apply to bodies corporate registered under the\nACNC Act\nItem Column 1 Column 2\nProvision(s) Topic\n2 section 138 ASIC may direct company to lodge\nconsolidated constitution\n3 section 139 Company must send copy of\nconstitution to member\n4 subsection 142(2), section 146 and Company must notify ASIC of\nsubsection 146A(2) changes of address\n5 (a) sections 180 to 183; and Duties of directors etc. (b) section 185, to the extent that it\nrelates to sections 180 to 183\n6 section 188, to the extent it relates to Responsibility of secretaries and\na provision mentioned in another directors for certain contraventions\nitem of this table\n7 sections 191 to 194 Interests of directors\n8 (a) sections 201L and 205A to 205C; Public information about directors\nand etc."}], "evidence_b": [{"chunk_id": "14cb9eb911d15322::42b::fe23", "source_doc": "2023_Response_PS_Regulations_Amendments.pdf", "page": 22, "passage": "LTD Question 1. MAS seeks comments on the proposed amendments to the Payment Services\nRegulations.\n1. The term safeguarding institution needs to be defined for the purposes of\nRegulation16C. Since DPTSP can self custodize it would be good to have a clear\ndefinition of safeguarding customer's assets. The term \"safeguarding\" is also not\nused/defined in Securities and Futures Act or in the Securities and Futures\n(licensing and conduct of business) regulations in the context of customer\nassets.\n2. It is not clear in these amendments whether a PSA license is a blanket license\nthat will allow the licensee to conduct all of the digital payment token services\n(i.e. broking dealing in DPT, DPT Exchange, DPT Custody) under one PSA license 2 April 2024 | 26\nor would a licensee be granted a PSA license for specific digital payment token\nservices? Trying to draw an analogy here from the Capital Market Services\nLicense (CMSL) where each CMSL holder is given a license outlining the activities\nthat they can do under the CMSL license.\n8 Interactive Brokers Question 1."}], "rationale": "The evidence for Regime A (AU_CORPS_ACT) focuses on the interaction with the Australian Charities and Not-for-profits Commission Act, detailing specific provisions regarding company constitutions, director duties, and winding up (chunk 0fc4f857c226f510::375::66b5). The evidence for Regime B (SG_PSA_GENERAL) discusses the regulatory scope of Payment Services Act licenses, specifically regarding Digital Payment Token Services (DPT) and whether a PSA license covers all activities like custody or requires specific licensing (chunk 14cb9eb911d15322::42b::fe23). The obligations in Regime A relate to corporate governance and internal company affairs, while the obligations in Regime B relate to financial services licensing and digital asset custody. These are distinct regulatory domains with no apparent overlap of specific obligations that would create a conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:56:31Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:bf89bd6004067df8b580f93d", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "a0d157539d5c8040::2fc::beb4", "source_doc": "FinalReport_Market_Abuse_Guidelines_MiCA.pdf", "page": 6, "passage": "2 Background and Legal Basis\nArticle 92 (3) of MiCA:\nIn order to ensure consistency of supervisory practices under this Article, ESMA shall by 30\nJune 2025 issue guidelines in accordance with Article 16 of Regulation (EU) No 1095/2010 on\nsupervisory practices among the competent authorities to prevent and detect market abuse, if\nnot already covered by the regulatory technical standards referred to in paragraph 2.\n\n1. To promote confidence in markets in crypto-assets and ensure their integrity, Title VI of\nMiCA lays down rules on prevention and prohibition of market abuse involving crypto\nassets.\n\n2. Article 92(1) of MiCA requires any PPAET in crypto-assets to have in place effective\narrangements, systems and procedures to prevent and detect market abuse."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "The EU_MICA passages describe the internal legal framework, supervisory practices, and authorisation requirements for crypto-asset service providers (e.g., Article 92(1) requiring effective arrangements for market abuse prevention, and Article 62(5) regarding application for authorisation). The SG_FOUNDATIONAL_LEGISLATION passages discuss MAS enforcement actions against ICO issuers and exchanges, and a consultation paper regarding the regulatory scope of securities contracts (SCS) and potential alignment with international standards like EU MiCA. The SG passage explicitly acknowledges EU MiCA as a regulatory standard for foreign SCS operating in Singapore (evidence_b_chunk_ids), indicating that the regimes are treated as distinct but potentially aligned frameworks rather than conflicting obligations. Therefore, the regimes are in different domains with no evidence of a direct conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:13:45Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:a26e28107acaab549e167c1d", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::340::9399", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 21, "passage": "1. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n2. MiCA sets out a new legal framework applicable to legal persons or other undertakings\nintending to provide crypto-asset services, requiring such entities to submit an\napplication for authorisation containing all the information set out in Article 62(2) of MiCA,\nas specified by the RTS on the information for authorisation as a CASP.\n\n3. The next paragraphs present the cost-benefit analysis of the main policy options included\nin this final report on the requirements for the application for authorisation as a CASP\nunder Article 62 of MiCA.\nProblem identification"}], "rationale": "The obligations in Regime A (AU_APRA_CPS230) focus on operational risk management, resilience, and the management of service providers for APRA-regulated entities. The obligations in Regime B (EU_MICA_TITLE_V_CASP) focus on the authorisation requirements for Crypto-Asset Service Providers (CASP) under the Markets in Crypto-Assets Regulation (MiCA). The passages describe distinct regulatory frameworks governing different sectors (general financial services vs. crypto-asset services) and different objectives (operational resilience vs. market integrity and investor protection). There is no specific obligation in Regime A that pushes against a specific obligation in Regime B; rather, they regulate separate domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:27:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:bca70a5e5c72e17ab7c1f293", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "SG_MAS_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "a82833dc0f7ca903::17a::c743", "source_doc": "Outsourcing_Guidelines_2018.pdf", "page": 3, "passage": "1.2 These Guidelines1 on Outsourcing (\"Guidelines\") set out the Monetary Authority of\nSingapore's (\"MAS\") expectations of an institution that has entered into any outsourcing\narrangement or is planning to outsource its business activities2 to a service provider. An\ninstitution should conduct a self-assessment of all existing outsourcing arrangements against\nthese Guidelines3."}], "rationale": "The evidence from AU_TREASURY_DAP discusses the Australian government's 'token mapping' exercise to identify how crypto assets fit into the financial services framework and outlines plans for future licensing reforms (chunk_id=d75262e404517e0c::47b::7c9f). The evidence from SG_MAS_OUTSOURCING outlines the Monetary Authority of Singapore's general expectations for institutions entering into outsourcing arrangements (chunk_id=a82833dc0f7ca903::17a::c743). The passages describe distinct policy agendas and regulatory frameworks for different jurisdictions (Australia and Singapore) and do not contain specific obligations that push against one another. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:ce5ce92ca2ee749f603f2bc3", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU AML/CTF (AUSTRAC guidance)"}, "regime_b": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU Travel Rule (IFTI)"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}], "evidence_b": [{"chunk_id": "561fc09c315f8349::45d::68bb", "source_doc": "Money transferred to and from overseas International funds transfer instruction (IFTI) reports.pdf", "page": null, "passage": "In\nan IFTI-E: e the transfer instruction is carried out or passed on electronically https://www.austrac.gov.au/business/core-guidance/reporting/money-transferred-and-overseas-international-funds-transfer-instruction-ifti-reports 2/6 25/06/2025, 23:15 Money transferred to and from overseas: International funds transfer instruction (IFTI) reports | AUSTRAC e the transfer is within the same financial institution or between financial\ninstitutions, such as banks, building societies or credit unions. An IFTI-E can be either:\ne outgoing - the ordering institution accepts the instruction in Australia and transfers money to the payee via a beneficiary institution overseas e incoming - the ordering institution accepts the instruction overseas and\ntransfers money via a beneficiary institution in Australia. Information required in IFTI-E reports\nIFTI-E reports must include details about everyone involved in the transfer:\ne the payer - the business, organisation or individual who instructs the ordering\ninstitution to transfer money\ne the ordering institution - the institution that accepts the transfer instruction"}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): AUSTRAC AML/CTF operational guidance and AUSTRAC IFTI / EFTI travel-rule reporting are designed to coexist — obligations apply cumulatively without collision. The AUSTRAC Travel Rule guidance is a narrowed view of the broader AML/CTF regime — same regime, different granularity. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-18T11:48:14Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:a0ed2510b7e6aaf0906c665c", "label": "conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "regime_b": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_AFSL"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::2bc::cafa", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 9, "passage": "19. Article 62(4) of MiCA sets out that NCAs must not require an applicant CASP to provide\nany information referred to in Article 62(2) of MiCA that they have already received under\nthe respective authorisation procedures in accordance with Directive 2009/110/EC4,\n2014/65/EU5 or (EU) 2015/23666, or pursuant to national law applicable to crypto-asset\nservices prior to the date of entry into force of MiCA, provided that such previously\nsubmitted information or documents are still up-to-date.\n\n3.2 Feedback statement\nQ2: Do you agree with the list of information to be provided with an application for\nauthorisation as a crypto-asset service provider? Please also state the reasons for your\nanswer."}], "evidence_b": [{"chunk_id": "8885979388bc0a29::52c::d4fe", "source_doc": "RG_1_Applying_for_AFS_Licence.pdf", "page": 38, "passage": "RG 1.187 AFS licensees have obligations under s912A requiring them to:\n(a) operate their business efficiently, honestly and fairly;\n(b) maintain the organisational competence to provide the financial services\ncovered by their licence;\n(c) ensure their representatives are competent and adequately trained to\nprovide the financial services;\n(d) have adequate financial, technological and human resources to provide\nthe financial services;\n(e) have risk management systems;\n(f) have arrangements in place for managing conflicts of interest;\n(g) comply with the financial services laws and ensure their representatives\ncomply with those laws;\n(h) comply with the conditions on their licence; and\n(i) if they are the operator of an Australian passport fund or a person with\nresponsibilities in relation to an Australian passport fund-comply with\nthe law of each host economy for the fund.\nNote 1: If you are an eligible body under ASIC Corporations (Foreign Financial Services\nProviders-Foreign AFS Licensees) Instrument 2020/198 you may be exempt from some\nof these obligations.\nNote 2: If you are providing financial services to retail clients, you will have additional\ndispute resolution and compensation obligations. Please see s912B for more information.\n© Australian Securities and Investments Commission June 2025 Page 38"}, {"chunk_id": "8885979388bc0a29::28c::e3b4", "source_doc": "RG_1_Applying_for_AFS_Licence.pdf", "page": 39, "passage": "RG 1.193 If we grant you an AFS licence, your licensee obligations include your\nstatutory obligations including those in s912A, the licence conditions imposed\nunder the Corporations Regulations including reg 7.6.04, and the licence\nconditions imposed by ASIC in PF 209, as well as any tailored licence\nconditions that apply specifically to you.\n© Australian Securities and Investments Commission June 2025 Page 39\n\nEfficiently, honestly and fairly\n\nRG 1.194 Section 912A(1)(a) requires that a financial services licensee do all things\nnecessary to ensure that the financial services covered by the licence are\nprovided efficiently, honestly and fairly."}], "rationale": "EU_MICA_TITLE_V_CASP (EU CASP authorisation framework — applies to any entity providing ten enumerated crypto-asset services to EU clients) and AU_ASIC_AFSL (Australian Financial Services Licence — extended by ASIC INFO 225 to crypto activities WHEN the underlying crypto-asset qualifies as a 'financial product' under the Corporations Act). When an entity operates crypto-asset services across both jurisdictions, whether AFSL is engaged at all turns on FACTS about the specific crypto-asset's characteristics (financial-product status determination per INFO 225 criteria). The interaction with MiCA CASP authorisation depends on whether AFSL applies — fact-sensitive determination yielding materially different combined obligations.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:59Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:11:54Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:43576a66a6ad45c6521bf8b6", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}, {"chunk_id": "28dfda0f6a6539b6::4f2::95d6", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Such a warning may be\nprovided in a standardised format;\n(d) the investment firm complies with its obligations under Article 23.\n5. The investment firm shall establish a record that includes the document or documents agreed between the\ninvestment firm and the client that set out the rights and obligations of the parties, and the other terms on which\nthe investment firm will provide services to the client. The rights and duties of the parties to the contract may be\nincorporated by reference to other documents or legal texts.\n6. The investment firm shall provide the client with adequate reports on the service provided in a durable medium. Those reports shall include periodic communications to clients, taking into account the type and the complexity of\nfinancial instruments involved and the nature of the service provided to the client and shall include, where applicable, the\ncosts associated with the transactions and services undertaken on behalf of the client. When providing investment advice, the investment firm shall, before the transaction is made, provide the client with a\nstatement on suitability in a durable medium specifying the advice given and how that advice meets the preferences,\nobjectives and other characteristics of the retail client."}], "rationale": "The evidence for APRA CPS 230 focuses on operational risk management, resilience, and the management of service providers (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c). The evidence for EU MIFID II focuses on product governance, suitability, and information disclosure obligations for investment firms (chunk_ids 28dfda0f6a6539b6::620::92ed, 28dfda0f6a6539b6::4f2::95d6). The obligations in MIFID II regarding product approval and client suitability do not impose conflicting requirements on the operational resilience or service provider management obligations outlined in CPS 230. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:04:03Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:45d66a6902838777b2787976", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "018117ef1e757630::4b5::9ef5", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Guidelines\n• MAS' surveillance efforts are • Existing VASPs operating in\nfocused on: (a) detecting and Singapore were required to notify\nLicensing\ndeterring unlicensed DPT activities MAS and submit licence\nSurveillance and\nin Singapore; and (b) leveraging applications by 28 Jul 2020.\ndata and blockchain analytics to Supervision\nidentify higher risk entities. • Applicants expected to\ndemonstrate understanding and\nability to mitigate ML/TF risks. Slide 5 (III) AML/CFT requirements for DPT sector\nAML/CFT requirements for digital payment token (DPT) service in Singapore\n• AML/CFT requirements are set out in MAS Notice PSN02 (issued 5 Dec 2019) and Guidelines to PSN02 (issued on 16 Mar 2020). Amendments to the Payment Services Act were passed in Parliament in Jan 2021 to expand the scope of DPT services and\nfurther updates to Notice PSN02 and Guidelines are in train to apply AML/CFT requirements to the newly scoped-in DPT services.\n• Entities that (a) deal in DPT; (b) facilitate the exchange of DPT; (c) facilitate the transmission of DPT; (d) and/or provide custodian\nwallet services, will therefore be required to be licensed as DPT service providers, and comply with the AML/CFT requirements."}], "rationale": "The evidence for AU_TRAVEL_RULE indicates that Australia has not yet implemented the FATF 'Travel Rule' for digital currency exchanges and is currently consulting on extending these requirements (cf7cefacba3f94bc::383::7d9d, 30a32a386d15ba2b::4f3::edc3). In contrast, the evidence for SG_PSA_DPT confirms that AML/CFT requirements, including the Travel Rule, are already applicable to Digital Payment Token (DPT) service providers in Singapore (018117ef1e757630::4b5::9ef5). The regimes are not in conflict because one is actively implementing a rule that the other is still considering; they operate in different stages of regulatory maturity regarding the same topic."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.78, "record_type": "non_conflict", "pair_id": "non_conflict:609cb06178c32bb99b326f03", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "GDPR"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}, {"chunk_id": "df546f2364aaf9e2::405::0d5b", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 30, "passage": "Member States shall ensure that supervisors have the power to disassociate persons convicted of money laundering,\nits relevant predicate offences or terrorist financing, who are beneficial owners of obliged entities as referred to in\nparagraphs 1 and 2, from obliged entities, including by granting supervisors the power to request the divestment of the\nholding by those beneficial owners in obliged entities.\n6. For the purposes of this Article, Member States shall ensure that, in accordance with national law, supervisors or any\nother authority competent at national level for assessing the requirements applicable to persons referred to in paragraphs 1\nand 2 of this Article, check the central AML/CFT database under Article 11 of Regulation (EU) 2024/1620 and whether\na relevant conviction exists in the criminal record of the person concerned. Any exchange of information for those\npurposes shall be carried out in accordance with Framework Decision 2009/315/JHA and Decision 2009/316/JHA as\nimplemented in national law.\n7."}], "evidence_b": [{"chunk_id": "bd84e63f5b622b73::5e9::a119", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 48, "passage": "Article 25\nData protection by design and by default\n1. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of\nprocessing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the\nprocessing, the controller shall, both at the time of the determination of the means for processing and at the time of the\nprocessing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are\ndesigned to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the\nnecessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of\ndata subjects.\n2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default,\nonly personal data which are necessary for each specific purpose of the processing are processed. That obligation applies\nto the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility.\nIn particular, such measures shall ensure that by default personal data are not made accessible without the individual's\nintervention to an indefinite number of natural persons.\n3. An approved certification mechanism pursuant to Article 42 may be used as an element to demonstrate\ncompliance with the requirements set out in paragraphs 1 and 2 of this Article."}, {"chunk_id": "bd84e63f5b622b73::4a6::7573", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 1, "passage": "Consistent and\nhomogenous application of the rules for the protection of the fundamental rights and freedoms of natural\npersons with regard to the processing of personal data should be ensured throughout the Union. Regarding the\nprocessing of personal data for compliance with a legal obligation, for the performance of a task carried out in\nthe public interest or in the exercise of official authority vested in the controller, Member States should be\nallowed to maintain or introduce national provisions to further specify the application of the rules of this\nRegulation. In conjunction with the general and horizontal law on data protection implementing Directive\n95/46/EC, Member States have several sector-specific laws in areas that need more specific provisions. This\nRegulation also provides a margin of manoeuvre for Member States to specify its rules, including for the\nprocessing of special categories of personal data ('sensitive data'). To that extent, this Regulation does not exclude\nMember State law that sets out the circumstances for specific processing situations, including determining more\nprecisely the conditions under which the processing of personal data is lawful."}], "rationale": "AMLD6 builds on the existing AML/CFT framework's interaction with GDPR — the AMLD framework has long included data-protection language (cross-referenced earlier in AMLD6 Recital 59 etc., which we cite in the recurring-friction pair AU_FEDREG_AML :: AU_PRIVACY's evidence pool). The lawful-basis chain (GDPR Art. 6(1)(c)) carries AMLD6 supervisory measures forward without colliding with GDPR's minimisation and purpose-limitation principles. Hard negative — these regimes have been designed to coexist for a decade.", "would_conflict_if": ["A specific AMLD6 transposition extended supervisory disclosure beyond a GDPR Art. 6(1)(c) carve-out — unlikely under the Directive's harmonisation regime."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:06:40Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:35c6e039b44249ae86578ae2", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::34a::74e3", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 11, "passage": "33. Article 109(1)(d) MiCA requires ESMA to establish a register of CASPs which must be\npublicly available on its website and be updated on a regular basis. Article 109(5) MiCA\nspecifies the information which the register must contain, including the name, legal form\nand legal entity identifier of the CASP and, where applicable, of the where applicable, of\nthe CASP's branches and the list of crypto-asset services provided by the CASP. To\nensure that an application for authorisation also contains all information required for the\nfuture ESMA public register of CASPs, ESMA proposes to include a few additional\ninformation requirements of limited extent to reflect the requirements of Article 109(5) of\nMiCA in the draft RTS on the application for authorisation as a CASP.\n\n4 Complaints-handling procedures of crypto-asset service\nproviders"}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::3c5::d461", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 33, "passage": "80. Despite the many and frequently changing marketing terms and innovative\nbusiness models developed in this sector, the FATF envisions very few VA\narrangements without VASPs involved at some stage if countries apply the\ndefinition correctly. Countries should take particular care to assess any claims that\nbusinesses may make as to models of decentralization or distributed services, and\nconduct their own assessment of the business model in line with its risk and their\nability to mitigate these risks.\n\n81. As previously stated, the FATF Standards are technology neutral. As such, the FATF\ndoes not seek to regulate the technology that underlies VAs or VASP activities.\nRather the FATF seeks to regulate natural or legal persons behind such technologies\n\n32  UPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS\nthat conduct as a business the aforementioned VASP activities on behalf of another\nnatural or legal person."}], "rationale": "The EU MiCA regime establishes a specific licensing and authorisation framework for Crypto-Asset Service Providers (CASP) within the EU (c51ad46265cea4e5::147::6214, c51ad46265cea4e5::34a::74e3). The FATF regime, conversely, defines VASPs as a minimum standard for countries to introduce and explicitly states that countries may choose to extend their AML/CFT regimes to include other digital assets and entities beyond the FATF definition (85240528438654b9::1cd::07d7, 85240528438654b9::3c5::d461). Furthermore, FATF guidance notes that countries need not impose a separate licensing system for entities already licensed as financial institutions (ba862e1f095bceac::1a6::1f0e). The passages describe distinct regulatory objectives: MiCA focuses on market conduct and authorisation requirements for EU entities, while FATF focuses on AML/CFT minimum standards and risk-based approaches. There is no evidence of a direct obligation in MiCA that conflicts with a specific obligation in FATF; rather, they operate in complementary domains (aligned_complementary)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:26:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:1f18c0f1bc0d869b5c6d6119", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "The EU MICA Title IV EMT regime regulates the disclosure and liability obligations of issuers of e-money tokens and asset-referenced tokens, specifically regarding the content of crypto-asset white papers and notification to competent authorities (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e). In contrast, the Singapore AML regime (MAS Notice 314) focuses on the training and compliance obligations of officers, employees, and agents regarding money laundering and terrorism financing (chunk_id 3d521e61e49aaf46::38f::e615). The obligations in the EU regime relate to financial product disclosure and issuer liability, while the Singapore obligations relate to internal controls and staff training for AML purposes. These are distinct regulatory domains that do not impose conflicting requirements on the same operational activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:5efad6bb97d403e4c6508cc3", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "evidence_b": [{"chunk_id": "018117ef1e757630::4b5::9ef5", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Guidelines\n• MAS' surveillance efforts are • Existing VASPs operating in\nfocused on: (a) detecting and Singapore were required to notify\nLicensing\ndeterring unlicensed DPT activities MAS and submit licence\nSurveillance and\nin Singapore; and (b) leveraging applications by 28 Jul 2020.\ndata and blockchain analytics to Supervision\nidentify higher risk entities. • Applicants expected to\ndemonstrate understanding and\nability to mitigate ML/TF risks. Slide 5 (III) AML/CFT requirements for DPT sector\nAML/CFT requirements for digital payment token (DPT) service in Singapore\n• AML/CFT requirements are set out in MAS Notice PSN02 (issued 5 Dec 2019) and Guidelines to PSN02 (issued on 16 Mar 2020). Amendments to the Payment Services Act were passed in Parliament in Jan 2021 to expand the scope of DPT services and\nfurther updates to Notice PSN02 and Guidelines are in train to apply AML/CFT requirements to the newly scoped-in DPT services.\n• Entities that (a) deal in DPT; (b) facilitate the exchange of DPT; (c) facilitate the transmission of DPT; (d) and/or provide custodian\nwallet services, will therefore be required to be licensed as DPT service providers, and comply with the AML/CFT requirements."}], "rationale": "FATF_R16 (FATF Recommendation 16 travel rule for VAs/VASPs) and SG_PSA_DPT (MAS's PSN02 AML notice for DPT licensees, which Singapore uses to implement the FATF travel rule). The B passage describes MAS's AML/CFT supervisory framework for DPT providers — directly implementing the FATF standards. Reinforcing relationship."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:43:41Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:3815424f4dc367c2d03a0201", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}], "rationale": "The AU_AML_CTF regime regulates Anti-Money Laundering and Counter-Terrorism Financing reporting obligations, specifically requiring reporting entities to give reports about suspicious matters, threshold transactions, and international funds transfer instructions (chunk_id 254ca2d92d196180::2ac::a5fe). The EU_MAR regime regulates market abuse, including insider dealing and market manipulation, to ensure the integrity of financial markets (chunk_id 5cc4a27bc578287a::165::3333). The obligations and subject matter of the two regimes are distinct; one focuses on financial crime prevention and reporting, while the other focuses on market integrity and trading conduct. There is no evidence of a specific obligation in AU_AML_CTF that conflicts with a specific obligation in EU_MAR."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:14:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:bb94533e56d700f0d7b406a1", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "rationale": "The AU_TTR_THRESHOLD regime regulates the reporting of physical currency transactions exceeding A$10,000 to AUSTRAC. The EU_EMD2 regime regulates digital operational resilience for the financial sector. The cited passages for EU_EMD2 refer to Directive (EU) 2022/2556 regarding digital operational resilience and do not contain any obligations related to physical currency reporting or transaction thresholds. Therefore, the obligations of the two regimes do not overlap, and there is no conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:f91ca73d7cbe047504847e04", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "550958b067dc6726::709::b159", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 15, "passage": "2.3 Overview of proposed framework\nLicensing\nThe proposed framework would recognise certain asset holding arrangements as a financial product (a\ndigital asset facility). The existing AFSL framework would apply to any person 'carrying on a financial\nservices business in Australia' in relation to a digital asset facility. Examples of 'financial services'\ninclude:\n• dealing in a financial product (including applying for or acquiring, issuing, varying or disposing of a\nfinancial product)\n• making a market for a financial product\n• providing a custodial or depository service, and\n• providing financial product advice.\nThe issuer of a digital asset facility would be the person or persons responsible for the obligations\nowed to customers under the terms of the asset holding arrangement (platform provider). Platform\nproviders and other intermediaries performing financial services in relation to digital asset facilities\n(e.g. brokers, arrangers, agents, market makers, and advisers) would be required to hold an AFSL.\nWhile the application of the AFSL regime would be jurisdictionally limited to Australia in the usual way,\nan intermediary business in Australia, like a broker, would need to be licensed to provide services that\ninvolve dealing in digital asset facilities generally (including those not licensed or located in Australia).\nSee Part 3 for further detail about licensing obligations.\nFacility contracts\nThe proposed framework would permit digital asset facilities to be paired with other functions,\ncreating digital asset platforms. All arrangements involving digital asset facilities would be required to\nbe structured as non-discretionary arrangements.29 The term 'non-discretionary' means the\narrangements must operate according to pre-agreed and transparent rules and procedures."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}], "rationale": "AU_ASIC_AFSL (Australian Financial Services Licence framework — proposed digital-asset facility licensing) and EU_MAR (EU Market Abuse Regulation 596/2014 — insider dealing / market manipulation). Both touch on market-conduct regulation but at different layers — AU AFSL is entity-licensing; EU MAR is market-abuse rules. Different jurisdictional perimeters and specific obligations; no direct conflict on cited passages."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:17:42Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9f2dbf3b49fac10c22200f8c", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DORA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::5f2::974e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 23, "passage": "Article 1\nSubject matter\n1. In order to achieve a high common level of digital operational resilience, this Regulation lays down uniform\nrequirements concerning the security of network and information systems supporting the business processes of financial\nentities as follows:\n(a) requirements applicable to financial entities in relation to:\n(i) information and communication technology (ICT) risk management;\n(ii) reporting of major ICT-related incidents and notifying, on a voluntary basis, significant cyber threats to the\ncompetent authorities;\n(iii) reporting of major operational or security payment-related incidents to the competent authorities by financial\nentities referred to in Article 2(1), points (a) to (d);\n(iv) digital operational resilience testing;\n(v) information and intelligence sharing in relation to cyber threats and vulnerabilities;\n(vi) measures for the sound management of ICT third-party risk;\n(b) requirements in relation to the contractual arrangements concluded between ICT third-party service providers and\nfinancial entities;\n(c) rules for the establishment and conduct of the Oversight Framework for critical ICT third-party service providers when\nproviding services to financial entities;\n(d) rules on cooperation among competent authorities, and rules on supervision and enforcement by competent\nauthorities in relation to all matters covered by this Regulation.\n2. In relation to financial entities identified as essential or important entities pursuant to national rules transposing"}], "rationale": "The evidence for AU_TREASURY_DAP focuses on the Australian government's 'token mapping' exercise to identify how crypto assets fit into existing financial services laws and the subsequent development of a licensing framework for crypto asset service providers (chunks 4905, 6bb9, 7c9f). The evidence for EU_DORA establishes a regulatory framework for the 'digital operational resilience' of financial entities, specifically regarding the security of network and information systems and ICT risk management (chunks 974e, 3d7, 2b9). The two regimes address distinct regulatory domains: one is a jurisdictional and product classification exercise for crypto assets (AU), while the other is a technical operational resilience standard for financial entities (EU). There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:57984e9811b6820ff4fd739b", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}], "rationale": "AU_TREASURY_DAP (Australia's proposed Digital Asset Platforms regime — Treasury consultation) and SG_PSA_GENERAL (Singapore Payment Services Act). Both regulate digital-asset / payment services in their respective jurisdictions, but with materially different mechanisms and licensing perimeters. No conflicting obligation on the cited passages."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:25:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:6aa095667c25f695222405ca", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "9a96d4d1812f257a::2a6::2422", "source_doc": "161011-APRA-RIS-margining-risk-mitigation-final-assessment-second-pass.pdf", "page": 2, "passage": "2 APRA's prudential framework comprises prudential standards and prudential practice guides (PPGs). APRA is\nempowered to issue legally binding prudential standards that set out specific requirements with which APRA-regulated\ninstitutions - authorised deposit-taking institutions (ADIs), general insurers and life companies (collectively,\ninsurers) and registrable superannuation entity licensees (RSE licensees) - must comply. APRA also issues PPGs,\nwhich clarify APRA's expectations with regard to prudential matters. PPGs frequently discuss legal requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements."}, {"chunk_id": "66d049e24f0863da::3f7::aec8", "source_doc": "Superannuation-Reporting-Standards-RIS.pdf", "page": 1, "passage": "1 INTRODUCTION\nThis Regulation Impact Statement (RIS) addresses the Australian Prudential Regulation\nAuthority's (APRA's) proposed introduction of new reporting standards applying to trustees of\nregistrable superannuation entities (RSE licensees). APRA is the prudential regulator of the superannuation, banking and insurance industries. Its\nmission is to ensure that, under all reasonable circumstances, financial promises made by APRA-\nregulated institutions are met within a stable, efficient and competitive financial system. APRA\ncarries out this mission through a multi-layered prudential framework that encompasses\nlicensing and supervision of institutions. For many years, APRA has had the power to make\nprudential standards implementing this framework for the banking and insurance industries. APRA is also empowered to make reporting standards under the Financial Sector (Collection of\nData) Act 2001 (FSCODA), which require regulated institutions to submit specified data through\nvarious reporting forms."}], "evidence_b": [{"chunk_id": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}, {"chunk_id": "c51ad46265cea4e5::462::80d8", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 76, "passage": "6.5 Annex V - Draft RTS pursuant to Article 62(5) of MiCA\nCOMMISSION DELEGATED REGULATION (EU) .../...\nof XXX\nsupplementing Regulation (EU) 2023/1114 of the European Parliament and of the\nCouncil with regard to regulatory technical standards specifying the information to be\nincluded in an application for authorisation as crypto-asset service provider\n(Text with EEA relevance)\nTHE EUROPEAN COMMISSION,\nHaving regard to the Treaty on the Functioning of the European Union,\nHaving regard to Regulation (EU) 2023/1114 of the European Parliament and of the Council\nof 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2012\nand (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/193718, and in particular\nArticle 62(5), third subparagraph, thereof,\nWhereas:\n(1) The information to be provided in an application for authorisation as crypto-asset service\nprovider should be sufficiently detailed and comprehensive to enable competent\nauthorities to assess whether an applicant meets the applicable requirements laid down\nin Title V and, where relevant, Title VI of Regulation (EU) 2023/1114."}], "rationale": "The evidence for AU_APRA_PRUDENTIAL focuses on the Australian prudential framework, specifically APRA's role in issuing prudential standards for banking, insurance, and superannuation entities, and the review of capital requirements and securitisation risks (chunk_ids 9a96d4d1812f257a::2a6::2422, 66d049e24f0863da::3f7::aec8). The evidence for EU_MICA describes the European legal framework for crypto-assets, including the provision of crypto-asset services and the requirements for authorisation as a crypto-asset service provider (chunk_ids f9082873c5d9ba9d::302::bbe0, c51ad46265cea4e5::462::80d8). The obligations and regulated entities in the Australian prudential regime (banks, insurers, superannuation) are distinct from the crypto-asset service providers regulated under the EU MiCA framework. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other, nor is there evidence of overlap in the regulated activities or entities. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:46:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:4ae9a33cdeedb96af45baf60", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + TFR"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}, {"chunk_id": "df546f2364aaf9e2::405::0d5b", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 30, "passage": "Member States shall ensure that supervisors have the power to disassociate persons convicted of money laundering,\nits relevant predicate offences or terrorist financing, who are beneficial owners of obliged entities as referred to in\nparagraphs 1 and 2, from obliged entities, including by granting supervisors the power to request the divestment of the\nholding by those beneficial owners in obliged entities.\n6. For the purposes of this Article, Member States shall ensure that, in accordance with national law, supervisors or any\nother authority competent at national level for assessing the requirements applicable to persons referred to in paragraphs 1\nand 2 of this Article, check the central AML/CFT database under Article 11 of Regulation (EU) 2024/1620 and whether\na relevant conviction exists in the criminal record of the person concerned. Any exchange of information for those\npurposes shall be carried out in accordance with Framework Decision 2009/315/JHA and Decision 2009/316/JHA as\nimplemented in national law.\n7."}], "evidence_b": [{"chunk_id": "c4024f4c4c1616cc::42d::44a4", "source_doc": "AMLR_Regulation_EU_2024-1624.pdf", "page": 2, "passage": "(5) Since the adoption of Directive (EU) 2015/849, recent developments in the Union's criminal law framework have\ncontributed to strengthening the prevention of and fight against money laundering, its predicate offences and\nterrorist financing. Directive (EU) 2018/1673 of the European Parliament and of the Council (9) has led to\na common understanding of the money laundering crime and its predicate offences. Directive (EU) 2017/1371 of\nthe European Parliament and of the Council (10) defined financial crimes affecting the Union's financial interest,\nwhich should also be considered predicate offences to money laundering. Directive (EU) 2017/541 of the European\nParliament and of the Council (11) has achieved a common understanding of the crime of terrorist financing. As\nthose concepts are now clarified in Union criminal law, it is no longer necessary for the Union's AML/CFT rules to\ndefine money laundering, its predicate offences or terrorist financing. Instead, the Union's AML/CFT framework\nshould be fully coherent with the Union's criminal law framework."}, {"chunk_id": "c4024f4c4c1616cc::2f8::0145", "source_doc": "AMLR_Regulation_EU_2024-1624.pdf", "page": 2, "passage": "(6) Harmonisation in the relevant area of criminal law enables a strong and coherent approach at Union level to the\nprevention of and fight against money laundering and its predicate offences, including corruption. At the same time,\nsuch an approach ensures that Member States that have adopted a broader approach to the definition of criminal\nactivities which constitute predicate offences for money laundering can continue to apply such an approach. For that\nreason, in line with Directive (EU) 2018/1673, any kind of punishable involvement in the commission of a predicate\noffence for money laundering as criminalised in accordance with national law should also be considered as\na criminal activity for the purposes of that Directive and of this Regulation."}], "rationale": "AMLD6 and AMLR are explicitly designed as two pieces of the same EU AML/CFT package — together with the TFR (Reg 2023/1113) and AMLA (Reg 2024/1620), they form the new framework governing AML/CFT in the Union. AMLD6 Recital 4 states 'this Directive is part of a comprehensive package'. AMLR contains the directly-applicable operational rules on obliged entities; AMLD6 covers supervisory and Member-State implementation matters. They are designed to dovetail, with no obligation in one pushing against any obligation in the other. Hard negative.", "would_conflict_if": ["AMLD6 transposition created a Member-State carve-out incompatible with AMLR's directly-applicable rules — the package design forecloses this by allocating subject-matter cleanly."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:09:33Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:29fa9679da2783bf4c84abcf", "label": "conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}, {"chunk_id": "0e996ae99839f19e::3d0::2bb3", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "2020Ed. Act 2012 20\n(2) An organisation must not -\n(a) as a condition of providing a product or service, require an\nindividual to consent to the collection, use or disclosure of\npersonal data about the individual beyond what is\nreasonable to provide the product or service to that\nindividual; or\n(b) obtain or attempt to obtain consent for collecting, using or\ndisclosing personal data by providing false or misleading\ninformationwithrespecttothecollection,useordisclosure\nof the personal data, or using deceptive or misleading\npractices. (3) Anyconsentgiveninanyofthecircumstancesinsubsection(2)\nis not validly given for the purposes of this Act. (4) InthisAct,referencestoconsentgiven,ordeemedtohavebeen\ngiven, by an individual for the collection, use or disclosure of\npersonal data about the individual include consent given, or deemed\nto have been given, by any person validly acting on that individual's\nbehalf for the collection, use or disclosure of such personal data."}], "rationale": "EU_MICA_TITLE_IV_EMT (EU MiCA Title IV — e-money token issuer framework, including issuer KYC obligations under Articles 51-52 white-paper requirements and AML/CFT under linked Regulation 2023/1113) and SG_PDPA (Singapore PDPA). EMT issuers conducting cross-border issuance to SG clients face the same KYC×privacy tension as MiCA CASPs — they must collect/transmit personal data of customers; PDPA restricts the SG-side flow. Operationally resolvable via PDPA s.13(b) carve-out. Same conflict family as MiCA Title V ↔ SG_PDPA.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:14Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:18:31Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f1a2e0e2acf8f1bbd75b574c", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "08b3db1cc7362f25::3bb::5dba", "source_doc": "Guidance-Correspondent-Banking-Services.pdf.coredownload.pdf", "page": null, "passage": "FATF GUIDANCE\nCORRESPONDENT\nBANKING SERVICES\nOCTOBER 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on correspondent banking services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/correspondent-banking-services.html\n© 2016 FATF/OECD."}], "rationale": "The EU_MAR regime regulates market integrity, specifically insider dealing and market manipulation (chunks 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The INT_FATF_GENERAL regime regulates anti-money laundering (AML) and counter-terrorist financing (CFT) standards (chunks fe52dd87e13dba41::261::59a4, 08b3db1cc7362f25::3bb::5dba). The obligations in MAR relate to the conduct of trading and the prevention of market abuse, while FATF obligations relate to the reporting of suspicious transactions and the integrity of the financial system against money laundering and terrorist financing. These are distinct regulatory domains with no specific obligation in MAR that directly conflicts with a specific obligation in FATF."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:13:47Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:8f773e6a09eb8df79fb4019c", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::4f1::4905", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "Treasury received substantial feedback\nfrom a range of stakeholders with industry-wide support for clarity on the regulatory settings for crypto\nassets. In particular, key stakeholders flagged the need to prioritise the 'token mapping' work, which\ninvolves reviewing a range of crypto assets to identify how they fit within the existing regulatory framework. Accordingly, to commence the reform agenda, I will prioritise the complex 'token mapping' work in 2022. Token mapping is a foundational piece of work to support Government to identify how crypto assets and\nrelated services ought to be regulated. It will also importantly aid the development of a licensing framework\nby assisting in demarcating the perimeter between financial product crypto assets (already the subject of\nfinancial services laws) and non-financial product crypto assets (that may warrant a separate crypto asset\nregulatory framework). Parliament House Canberra ACT 2600 Australia\nOFFICIAL: Sensitive OFFICIAL: Sensitive Subject to your agreement, I propose to announce the reform agenda, commence stakeholder consultations\nand release a public consultation paper on token mapping in 2022 (as indicated in Treasury's earlier\nconsultation paper on crypto licensing and custody requirements)."}, {"chunk_id": "e6bb47e92e88e16c::37a::29f6", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 12, "passage": "16. After token mapping, licensing and custody reforms are the logical next step for crypto reforms\nin Australia. The identification of appropriate obligations and operational standards for crypto\nasset service providers and how they safe-keep assets for customers is a key step for consumer\nprotection; ensuring consumers do not lose assets to avoidable business failure or misuse of\nassets by the provider.\n\n17. The Government will release a consultation paper proposing a licensing and custody framework\nfor crypto asset service providers in mid-2023 to allow for sufficient consultation prior to the\nintroduction of legislation. The paper will reflect ongoing work and consultation in this area and\nleverage the findings from the token mapping exercise. The responses to the following\nquestions will help inform the general direction of future policy and potential consumer\nprotections."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "ffa7a3de1e0fc7f0::7bc::38ba", "source_doc": "d426.pdf", "page": 7, "passage": "1. General remarks\nThe Basel III framework is a central element of the Basel Committee's response to the global financial crisis.\nIt addresses a number of shortcomings with the pre-crisis regulatory framework and provides a regulatory\nfoundation for a resilient banking system that supports the real economy.\nThe Committee's finalisation of the Basel III reforms1 complements the improvements made to\nthe global regulatory framework from the initial phase of the Basel III framework. The revisions seek to\nrestore credibility in the calculation of risk-weighted assets (RWA) and therefore also capital ratios by:\n• enhancing the robustness and risk sensitivity of the standardised approaches for credit risk and\noperational risk, which will help facilitate the comparability of banks' capital ratios;\n• constraining the use of internally modelled approaches, by placing limits on certain inputs used\nto calculate RWA under the internal ratings-based (IRB) approach for credit risk and by removing\nthe use of the modelled approach for operational risk;\n• finalising the leverage ratio, which now includes a buffer to further limit the leverage of global\nsystemically important banks (G-SIBs); and\n• replacing the existing Basel I-based floor with a robust aggregate 72.5% output floor based on\nthe Committee's revised standardised approaches.\nIn order to analyse the impact of the revised standards, the Committee conducted an ad hoc\nBasel III monitoring exercise with the data collection starting in April 2016, in addition to its regular Basel III\nmonitoring exercise2 and the data collection exercise from regulatory reporting systems. This report\nsummarises the aggregate cumulative quantitative impact study results using data jointly from all three\nexercises. The Committee believes that the information contained in the report will provide relevant\nstakeholders with a useful benchmark for analysis as well as provide an estimated impact of the recently\nagreed upon reforms."}], "rationale": "The AU_TREASURY_DAP passages discuss the Australian government's 'token mapping' exercise and the development of a licensing framework for crypto asset service providers (chunk_ids d75262e404517e0c::4f1::4905, e6bb47e92e88e16c::37a::29f6). In contrast, the INT_BASEL_GENERAL passages address the Basel III framework's treatment of leverage ratios, general provisions, and expected losses for banks (chunk_ids 32afd37cade34f84::34b::8d30, ffa7a3de1e0fc7f0::7bc::38ba). The obligations and subject matter of the two regimes are distinct; one regulates crypto asset service providers in Australia, while the other regulates capital adequacy and leverage for banks globally. Therefore, there is no specific obligation in one regime that pushes against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:06:45Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:56642b13f1a5e4c5eeed6d71", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "rationale": "The AU_TRAVEL_RULE passages discuss Australia's regulatory framework for digital currency exchanges and the implementation of FATF's 'Travel Rule' for identifying parties in transactions. The EU_EMD2 passages refer to the Digital Operational Resilience Act (DORA) and financial sector operational resilience. The obligations in the AU passages (AML/CTF compliance and Travel Rule implementation) do not conflict with the obligations in the EU passages (digital operational resilience and financial rules). The regimes regulate different aspects of the financial sector—AML/CTF compliance versus operational resilience—resulting in a non-conflict relationship."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:48:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:7ba9332f8a9e793adc6bace6", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLD6"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}, {"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "The EU AMLD6 passage (chunk 85307f9e2a040982::14a::134d) discusses the scope of the Directive, specifically mentioning its application to the financial sector and digital operational resilience. The SG FSMA DTSP passages (chunks 20d526d712753652::404::80be and cc1be49e9cf8c821::2f4::ea8f) regulate Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022, defining their licensing requirements and operational obligations. While both regimes address the digital token sector and AML/CFT standards, the EU passage does not impose specific obligations that conflict with the Singaporean licensing and operational requirements for DTSPs. The SG passages focus on local licensing, exemptions, and FATF alignment, which are complementary rather than conflicting with the general scope of the EU Directive. Therefore, the regimes are in different domains regarding specific operational obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:57:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:556f6e7e76aee4618b8f937d", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "rationale": "The AU_AML_CTF regime regulates reporting obligations for suspicious matters, threshold transactions, and international funds transfer instructions (chunk 254ca2d92d196180::2ac::a5fe). The EU_REVERSE_SOLICITATION regime regulates the exemption from authorisation requirements for third-country crypto-asset firms when a client initiates the relationship (reverse solicitation) (chunk 25cbbd878a1b21d3::4f8::561c). The obligations in the EU regime relate to the initiation of a business relationship and marketing activities, whereas the AU regime focuses on reporting specific transactions and suspicious activities. There is no specific obligation in the AU regime that pushes against the reverse solicitation exemption in the EU regime; they regulate distinct aspects of financial services compliance."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:09:33Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.82, "record_type": "conflict", "pair_id": "conflict:f8141116c60f9c3395173d0e", "label": "conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "EU_MICA (EU Markets in Crypto-Assets Regulation — comprehensive framework including CASP AML obligations and crypto-asset transfer information requirements) and SG_PDPA (Singapore PDPA — consent and cross-border disclosure restrictions). EU CASPs operating across to SG must transmit personal data of senders/recipients for AML compliance; SG PDPA restricts the SG-side collection/disclosure absent the 'required by law' carve-out. Operationally resolvable via PDPA s.13(b) + SG MAS AML notices providing the SG legal basis. Same shape as labelled EU TFR ↔ EU GDPR conflict, in EU↔SG cross-jur framing.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:10Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:46:59Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:5551e9b7cbb045729f58d7cf", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "evidence_b": [{"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}], "rationale": "The EU DAC8 regime regulates the automatic exchange of tax information regarding crypto-asset users between Member States and non-Union jurisdictions (c0300673081f7232::320::7b46, c0300673081f7232::498::163c). The SG_PSA_GENERAL regime regulates the licensing and conduct of business for digital payment token service providers in Singapore (321e082bdbe732d3::309::b080). The obligations in DAC8 relate to tax reporting and administrative cooperation, while the obligations in SG_PSA_GENERAL relate to financial services licensing and operational conduct. There is no specific obligation in SG_PSA_GENERAL that pushes against a specific obligation in DAC8, nor is there evidence of a direct regulatory conflict between the two regimes."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:07:27Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:e660a834f71c4c5ec36bfc95", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "rationale": "The evidence from Regime A (AU_FEDREG_AML) focuses on Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations, specifically regarding reporting entities, customer identification, and suspicious transaction reporting (chunk cf7cefacba3f94bc::49a::f39e). The evidence from Regime B (INT_BASEL_CRYPTO) focuses on capital requirements and prudential standards for banks, defining bank exposures and risk-weighting methodologies (chunk 32afd37cade34f84::3a4::1a5b). The obligations in Regime A relate to financial crime prevention and customer due diligence, while the obligations in Regime B relate to banking stability and capital adequacy. These are distinct regulatory domains that do not impose conflicting obligations on the same activity."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:cb73242432455e757cfeb09d", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DAC 8 (crypto tax)"}, "regime_b": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "NIS 2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::4d9::6684", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 25, "passage": "B. Due diligence procedures for Entity Crypto-Asset Users\nThe following procedures apply for the purpose of determining whether the Entity Crypto-Asset User is a Reportable\nUser or an Entity, other than an Excluded Person or an Active Entity, with one or more Controlling Persons who are\nReportable Persons.\n1. Determine whether the Entity Crypto-Asset User is a Reportable Person. (a) When establishing the relationship with the Entity Crypto-Asset User, or with respect to Pre-existing Entity\nCrypto-Assets Users by 1 January 2027, the Reporting Crypto-Asset Service Provider shall obtain a self-\ncertification that allows the Reporting Crypto-Asset Service Provider to determine the Entity Crypto-Asset\nUser's residence(s) for tax purposes and confirm the reasonableness of such self-certification based on the\ninformation obtained by the Reporting Crypto-Asset Service Provider, including any documentation collected\npursuant to Customer Due Diligence Procedures. If the Entity Crypto-Asset User certifies that it has no\nresidence for tax purposes, the Reporting Crypto-Asset Service Provider may rely on the place of effective\nmanagement or the address of the principal office to determine the residence of the Entity Crypto-Asset User."}], "evidence_b": [{"chunk_id": "20d29e9c5300ae10::265::c962", "source_doc": "NIS2_Directive_EU_2022-2555.pdf", "page": 17, "passage": "(83) Essential and important entities should ensure the security of the network and information systems which they use\nin their activities. Those systems are primarily private network and information systems managed by the essential\nand important entities' internal IT staff or the security of which has been outsourced. The cybersecurity risk-\nmanagement measures and reporting obligations laid down in this Directive should apply to the relevant essential\nand important entities regardless of whether those entities maintain their network and information systems\ninternally or outsource the maintenance thereof."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU DAC 8 crypto-asset tax-reporting directive and EU NIS 2 horizontal cybersecurity directive operate in disjoint regulatory domains at the obligation level. Crypto-tax reporting vs cybersecurity directive — disjoint subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:53:40Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:cf18066ef38ef7a295ea2656", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The EU DAC8 regime focuses on tax transparency and administrative cooperation regarding crypto-asset reporting to tax authorities (chunk_ids c0300673081f7232::320::7b46, c0300673081f7232::498::163c). The INT IOSCO GENERAL regime focuses on securities regulation, market integrity, and disclosure standards for issuers and securities markets (chunk_id f173909614befd49::455::1a1a). The obligations in DAC8 relate to tax information exchange, while IOSCO's obligations relate to securities market conduct and disclosure. These are distinct regulatory domains with no apparent overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:40:04Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:3e72f5e494b6f75348993f73", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "018117ef1e757630::428::d321", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Strengthening AML/CFT Controls of\nDigital Payment Token Service Providers\nMarch 2021 Introduction\nThis infographic sets out recent international developments and MAS' supervisory expectations on\nAML/CFT controls for the Digital Payment Token (DPT) sector.\n• This infographic is intended to raise industry awareness to the money laundering and terrorism financing (ML/TF)\nrisks in the DPT sector, and provide additional supervisory information to help DPT service providers implement\neffective policies, procedures and controls to deal with the ML/TF risks.\n• In particular, this infographic focuses on:\nI) Financial Action Task Force (FATF) Standards and recent developments;\nII) ML/TF Risks in DPT sector; and\nIII) Overview of MAS' AML/CFT requirements and expectations for the DPT sector - including key AML/CFT\nconsiderations relating to new DPT products, enhanced customer due diligence (ECDD) and value transfer.\n• The infographic supplements existing AML/CFT requirements, and should be read in conjunction with the Notice\nPS-N02 and accompanying Guidelines."}], "rationale": "The AU Travel Rule passages describe a regulatory gap where Australia has not yet implemented the FATF Travel Rule for digital currency exchanges, noting that the rule would require identifying parties in transactions (chunk_ids cf7cefacba3f94bc::383::7d9d, 30a32a386d15ba2b::4f3::edc3). The SG AML passages, specifically the infographic on Digital Payment Token Service Providers, state that MAS' AML/CFT requirements and expectations for the DPT sector include key considerations relating to value transfer (chunk_id 018117ef1e757630::428::d321). The SG regime addresses the operational implementation of AML/CFT controls for DPTs, whereas the AU regime discusses the status of implementing the Travel Rule. The regimes are not in conflict; they address different aspects of the same regulatory landscape (implementation status vs. operational requirements)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:56:18Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:0222d79c8c87dd3178a44688", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}, {"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "rationale": "The obligations in Prudential Standard CPS 230 (Regime A) focus on operational resilience, business continuity, and the management of service providers to ensure an APRA-regulated entity can maintain critical operations through disruptions. In contrast, the FATF passages (Regime B) address Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) standards, specifically regarding digital identity and virtual assets. The specific obligations in CPS 230 regarding operational risk and resilience do not impose conflicting requirements on the AML/CFT obligations outlined in the FATF guidance. The regimes regulate distinct domains—prudential resilience versus financial crime prevention—resulting in no operational friction."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:09:13Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f8c242cb7f21fb66d5e913de", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "d7502c011527b67c::3e7::ae26", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 13, "passage": "This Regulation shall not apply to a transfer of funds where any of the following conditions is met:\n(a) it involves the payer withdrawing cash from the payer's own payment account;\n(b) it constitutes a transfer of funds to a public authority as payment for taxes, fines or other levies within a Member\nState;\n(c) both the payer and the payee are payment service providers acting on their own behalf;\n(d) it is carried out through cheque images exchanges, including truncated cheques. This Regulation shall not apply to a transfer of crypto-assets where any of the following conditions is met:\n(a) both the originator and the beneficiary are crypto-asset service providers acting on their own behalf;\n(b) the transfer constitutes a person-to-person transfer of crypto-assets carried out without the involvement of a crypto-\nasset service provider. Electronic money tokens, as defined in Article 3(1), point (7), of Regulation (EU) 2023/1114, shall be treated as crypto-\nassets under this Regulation."}], "rationale": "The evidence for Regime A (AU_APRA_CPS230) focuses on operational resilience, business continuity, and the management of service providers to ensure critical operations continue through disruptions (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c). The evidence for Regime B (EU_AMLR_TFR) addresses the scope of anti-money laundering obligations regarding the transfer of funds and crypto-assets, specifically excluding certain transfers like those between crypto-asset service providers acting on their own behalf (chunk_id d7502c011527b67c::3e7::ae26). The obligations in Regime A relate to the continuity and resilience of operations, while Regime B relates to the traceability and compliance of financial transactions. These are distinct regulatory domains with no specific obligation in one regime pushing against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:57:52Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:a340da2b03248ffcd200bd09", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "0fc4f857c226f510::375::66b5", "source_doc": "Corporations_Act_2001_Vol1.pdf", "page": 296, "passage": "Part 1.6 Interaction with Australian Charities and Not-for-profits Commission Act Section 111L\nProvisions of this Act that do not apply to bodies corporate registered under the\nACNC Act\nItem Column 1 Column 2\nProvision(s) Topic\n2 section 138 ASIC may direct company to lodge\nconsolidated constitution\n3 section 139 Company must send copy of\nconstitution to member\n4 subsection 142(2), section 146 and Company must notify ASIC of\nsubsection 146A(2) changes of address\n5 (a) sections 180 to 183; and Duties of directors etc. (b) section 185, to the extent that it\nrelates to sections 180 to 183\n6 section 188, to the extent it relates to Responsibility of secretaries and\na provision mentioned in another directors for certain contraventions\nitem of this table\n7 sections 191 to 194 Interests of directors\n8 (a) sections 201L and 205A to 205C; Public information about directors\nand etc."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "The evidence from Regime A (AU_CORPS_ACT) focuses on the interaction with the Australian Charities and Not-for-profits Commission Act, detailing specific provisions regarding company constitutions, director duties, and winding up (chunk 0fc4f857c226f510::375::66b5). The evidence from Regime B (SG_PSA_DPT) concerns the issuance of a Monetary Authority of Singapore Notice regarding AML/CFT obligations for holders of payment service licences providing digital payment token services (chunk 4b4c3c417dc293ba::185::f41d). The obligations and regulatory frameworks described in the two passages address distinct subject matters—corporate governance and charity regulation versus financial services licensing and AML compliance—and do not impose conflicting requirements on the same entity or transaction type."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:55:33Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:edeaca71cd4193224cf5d914", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::41f::546c", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 24, "passage": "3.1 Standard AFSL Obligations\nAustralian financial services licence\n(a) A platform provider must hold an AFSL authorising them to issue and deal in digital asset facilities.\n(b) A platform provider is exempt from holding an AFSL for digital asset facilities if:\n(i) the total value of platform entitlements held by any one client of the platform provider does\nnot exceed $1,500 at any one time; and\n(ii) the total amount of assets held by the platform provider does not exceed $5 million at any\ntime.\nInfo Box 3 Low value exemption\nThe risks with digital asset facilities are correlated to the size and scale of the asset holding role of\nthe platform provider. Accordingly, a 'low-value facility' exemption would be introduced, similar to\nthe 'low value facility' exemption for non-cash payment facilities. It would apply to digital asset\nfacilities holding less than $1,500 per customer and less than $5 million in total.40 This exemption\nis intended to allow for innovation and experimentation in the early stages of developing a novel\nservice offering."}, {"chunk_id": "550958b067dc6726::709::b159", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 15, "passage": "2.3 Overview of proposed framework\nLicensing\nThe proposed framework would recognise certain asset holding arrangements as a financial product (a\ndigital asset facility). The existing AFSL framework would apply to any person 'carrying on a financial\nservices business in Australia' in relation to a digital asset facility. Examples of 'financial services'\ninclude:\n• dealing in a financial product (including applying for or acquiring, issuing, varying or disposing of a\nfinancial product)\n• making a market for a financial product\n• providing a custodial or depository service, and\n• providing financial product advice.\nThe issuer of a digital asset facility would be the person or persons responsible for the obligations\nowed to customers under the terms of the asset holding arrangement (platform provider). Platform\nproviders and other intermediaries performing financial services in relation to digital asset facilities\n(e.g. brokers, arrangers, agents, market makers, and advisers) would be required to hold an AFSL.\nWhile the application of the AFSL regime would be jurisdictionally limited to Australia in the usual way,\nan intermediary business in Australia, like a broker, would need to be licensed to provide services that\ninvolve dealing in digital asset facilities generally (including those not licensed or located in Australia).\nSee Part 3 for further detail about licensing obligations.\nFacility contracts\nThe proposed framework would permit digital asset facilities to be paired with other functions,\ncreating digital asset platforms. All arrangements involving digital asset facilities would be required to\nbe structured as non-discretionary arrangements.29 The term 'non-discretionary' means the\narrangements must operate according to pre-agreed and transparent rules and procedures."}], "evidence_b": [{"chunk_id": "14cb9eb911d15322::42b::fe23", "source_doc": "2023_Response_PS_Regulations_Amendments.pdf", "page": 22, "passage": "LTD Question 1. MAS seeks comments on the proposed amendments to the Payment Services\nRegulations.\n1. The term safeguarding institution needs to be defined for the purposes of\nRegulation16C. Since DPTSP can self custodize it would be good to have a clear\ndefinition of safeguarding customer's assets. The term \"safeguarding\" is also not\nused/defined in Securities and Futures Act or in the Securities and Futures\n(licensing and conduct of business) regulations in the context of customer\nassets.\n2. It is not clear in these amendments whether a PSA license is a blanket license\nthat will allow the licensee to conduct all of the digital payment token services\n(i.e. broking dealing in DPT, DPT Exchange, DPT Custody) under one PSA license 2 April 2024 | 26\nor would a licensee be granted a PSA license for specific digital payment token\nservices? Trying to draw an analogy here from the Capital Market Services\nLicense (CMSL) where each CMSL holder is given a license outlining the activities\nthat they can do under the CMSL license.\n8 Interactive Brokers Question 1."}], "rationale": "The evidence for the Australian regime (Regime A) focuses on the requirement for a platform provider to hold an Australian Financial Services Licence (AFSL) to issue and deal in digital asset facilities, and the specific financial requirements (e.g., NTA) associated with that licence. The evidence for the Singapore regime (Regime B) discusses the definition of 'safeguarding institution' and the nature of a Payment Services (PS) license, specifically whether it is a blanket license for all digital payment token services or specific to certain activities. The obligations in Regime A (holding an AFSL and meeting financial requirements) do not directly oppose the obligations or scope definitions in Regime B (PS license types and safeguarding definitions). The regimes regulate the licensing and conduct of digital asset intermediaries in their respective jurisdictions, but the specific obligations cited do not create a conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:e94cf2a0fc046ed25b8fb93b", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "08b3db1cc7362f25::3bb::5dba", "source_doc": "Guidance-Correspondent-Banking-Services.pdf.coredownload.pdf", "page": null, "passage": "FATF GUIDANCE\nCORRESPONDENT\nBANKING SERVICES\nOCTOBER 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on correspondent banking services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/correspondent-banking-services.html\n© 2016 FATF/OECD."}], "rationale": "INT_BASEL_CRYPTO (Basel prudential treatment of crypto exposures by banks) and INT_FATF_GENERAL (FATF AML/CFT general standards). Both are international standards bodies that develop coordinated frameworks for global financial regulation — Basel on prudential and FATF on AML. They are structurally complementary pillars of international financial regulation; the cited passages confirm distinct but coordinated concerns."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:053d6aedfdcc7282e13919f5", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "d7502c011527b67c::3e7::ae26", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 13, "passage": "This Regulation shall not apply to a transfer of funds where any of the following conditions is met:\n(a) it involves the payer withdrawing cash from the payer's own payment account;\n(b) it constitutes a transfer of funds to a public authority as payment for taxes, fines or other levies within a Member\nState;\n(c) both the payer and the payee are payment service providers acting on their own behalf;\n(d) it is carried out through cheque images exchanges, including truncated cheques. This Regulation shall not apply to a transfer of crypto-assets where any of the following conditions is met:\n(a) both the originator and the beneficiary are crypto-asset service providers acting on their own behalf;\n(b) the transfer constitutes a person-to-person transfer of crypto-assets carried out without the involvement of a crypto-\nasset service provider. Electronic money tokens, as defined in Article 3(1), point (7), of Regulation (EU) 2023/1114, shall be treated as crypto-\nassets under this Regulation."}], "rationale": "AU_FEDREG_AML (Australian AML/CTF Act and Rules — AUSTRAC reporting entity framework) and EU_AMLR_TFR (EU's AMLR + TFR framework — Regulation 2023/1113). Both jurisdictions implement comparable AML/CFT obligations on regulated entities consistent with FATF standards. Entities operating across both face complementary (not contradictory) duties. The cited B passage notes specific scope exclusions in the EU TFR that are jurisdiction-specific but don't conflict with the AU framework."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T06:30:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.72, "record_type": "conflict", "pair_id": "conflict:32093b768e3ab6abd7176d24", "label": "conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DAC 8"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "GDPR"}, "conflict_type": "recurring_friction", "severity": "medium", "evidence_a": [{"chunk_id": "c0300673081f7232::4d9::6684", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 25, "passage": "B. Due diligence procedures for Entity Crypto-Asset Users\nThe following procedures apply for the purpose of determining whether the Entity Crypto-Asset User is a Reportable\nUser or an Entity, other than an Excluded Person or an Active Entity, with one or more Controlling Persons who are\nReportable Persons.\n1. Determine whether the Entity Crypto-Asset User is a Reportable Person. (a) When establishing the relationship with the Entity Crypto-Asset User, or with respect to Pre-existing Entity\nCrypto-Assets Users by 1 January 2027, the Reporting Crypto-Asset Service Provider shall obtain a self-\ncertification that allows the Reporting Crypto-Asset Service Provider to determine the Entity Crypto-Asset\nUser's residence(s) for tax purposes and confirm the reasonableness of such self-certification based on the\ninformation obtained by the Reporting Crypto-Asset Service Provider, including any documentation collected\npursuant to Customer Due Diligence Procedures. If the Entity Crypto-Asset User certifies that it has no\nresidence for tax purposes, the Reporting Crypto-Asset Service Provider may rely on the place of effective\nmanagement or the address of the principal office to determine the residence of the Entity Crypto-Asset User."}, {"chunk_id": "c0300673081f7232::5e7::e6a8", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 25, "passage": "SECTION III\nDUE DILIGENCE PROCEDURES\nA Crypto-Asset User is treated as a Reportable User beginning as of the date when it is identified as such pursuant to the due\ndiligence procedures described in this Section. A. Due diligence procedures for Individual Crypto-Asset Users\nThe following procedures apply for the purpose of determining whether the Individual Crypto-Asset User is a\nReportable User.\n1. When establishing the relationship with the Individual Crypto-Asset User, or with respect to Pre-existing Individual\nCrypto-Asset Users by 1 January 2027, the Reporting Crypto-Asset Service Provider shall obtain a self-certification\nthat allows the Reporting Crypto-Asset Service Provider to determine the Individual Crypto-Asset User's residence(s)\nfor tax purposes and confirm the reasonableness of such self-certification based on the information obtained by the\nReporting Crypto-Asset Service Provider, including any documentation collected pursuant to Customer Due\nDiligence Procedures.\n2. If at any point there is a change of circumstances with respect to an Individual Crypto-Asset User that causes the\nReporting Crypto-Asset Service Provider to know, or have reason to know, that the original self-certification is\nincorrect or unreliable, the Reporting Crypto-Asset Service Provider cannot rely on the original self-certification\nand shall obtain a valid self-certification, or a reasonable explanation and, where appropriate, documentation\nsupporting the validity of the original self-certification."}, {"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}], "evidence_b": [{"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "bd84e63f5b622b73::5e6::a9fd", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 62, "passage": "Article 46\nTransfers subject to appropriate safeguards\n1. In the absence of a decision pursuant to Article 45(3), a controller or processor may transfer personal data to a\nthird country or an international organisation only if the controller or processor has provided appropriate safeguards,\nand on condition that enforceable data subject rights and effective legal remedies for data subjects are available.\n2. The appropriate safeguards referred to in paragraph 1 may be provided for, without requiring any specific authoris\nation from a supervisory authority, by:\n(a) a legally binding and enforceable instrument between public authorities or bodies;\n(b) binding corporate rules in accordance with Article 47;\n(c) standard data protection clauses adopted by the Commission in accordance with the examination procedure referred\nto in Article 93(2);\n(d) standard data protection clauses adopted by a supervisory authority and approved by the Commission pursuant to\nthe examination procedure referred to in Article 93(2);\n(e) an approved code of conduct pursuant to Article 40 together with binding and enforceable commitments of the\ncontroller or processor in the third country to apply the appropriate safeguards, including as regards data subjects'\nrights; or\n(f) an approved certification mechanism pursuant to Article 42 together with binding and enforceable commitments of\nthe controller or processor in the third country to apply the appropriate safeguards, including as regards data\nsubjects' rights.\n3."}, {"chunk_id": "bd84e63f5b622b73::4a6::7573", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 1, "passage": "Consistent and\nhomogenous application of the rules for the protection of the fundamental rights and freedoms of natural\npersons with regard to the processing of personal data should be ensured throughout the Union. Regarding the\nprocessing of personal data for compliance with a legal obligation, for the performance of a task carried out in\nthe public interest or in the exercise of official authority vested in the controller, Member States should be\nallowed to maintain or introduce national provisions to further specify the application of the rules of this\nRegulation. In conjunction with the general and horizontal law on data protection implementing Directive\n95/46/EC, Member States have several sector-specific laws in areas that need more specific provisions. This\nRegulation also provides a margin of manoeuvre for Member States to specify its rules, including for the\nprocessing of special categories of personal data ('sensitive data'). To that extent, this Regulation does not exclude\nMember State law that sets out the circumstances for specific processing situations, including determining more\nprecisely the conditions under which the processing of personal data is lawful."}], "rationale": "DAC8 imposes ongoing reporting and due-diligence obligations on Reporting Crypto-Asset Service Providers (Annex III): collection and exchange of identifying personal information on Reportable Users — both individuals and entity controlling persons — and onward administrative exchange between Member State tax authorities (and, under Recital 19, to non-Union jurisdictions in defined cases). GDPR Articles 5(1)(b)-(c) and 44-49 push toward data minimisation, purpose limitation and tight controls on third-country transfers. The lawful-basis question is resolved (Article 6(1)(c) — legal obligation), so this is not structural_unresolved; but the cost recurs every reporting cycle as new personal data is collected and transmitted. Practitioners must continuously calibrate retention windows, data-protection-by-design for the reporting infrastructure, and transfer-impact assessments when administrative cooperation reaches non-EEA jurisdictions.", "compliant_paths": ["Operate DAC8 reporting on Art. 6(1)(c) (legal obligation) as the lawful basis; document Art. 5(1)(e) retention windows tied to the DAC8 retention requirement.", "For onward transfer to non-Union jurisdictions, rely on Art. 96 (administrative cooperation under Union law) or Art. 49 derogations as appropriate."], "out_of_scope_assumptions": ["Reporting CASP is established in or operates a Branch in a Member State."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:e702650561708bbd6246c354", "label": "conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "FATF_R16 (FATF Recommendation 16 — VA travel rule requiring sharing of originator/beneficiary personal data) and SG_PDPA (Singapore Personal Data Protection Act). FATF R16 implementations (including SG's via MAS PSN02) require sharing personal data of senders/recipients; PDPA's consent and disclosure restrictions engage. Operationally resolvable via PDPA s.13(b) ('required or authorised by law') for AML compliance. Same cross-jurisdictional AML-privacy shape.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:57Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.84, "record_type": "non_conflict", "pair_id": "non_conflict:09b295d835af6b7e4f490286", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AML/CTF Act + Rules"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + Transfer of Funds Regulation"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}, {"chunk_id": "c4a92930a8caf822::3d3::a52b", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 48, "passage": "Part 5 AML/CTF programs\nDivision 2 AML/CTF policies related to ML/TF risk mitigation\nSection 5-2\nDivision 2-AML/CTF policies related to ML/TF risk mitigation\n5-2 Carrying out customer due diligence\n(1) For the purposes of paragraph 26F(7)(a) of the Act, this section specifies\nrequirements in relation to the matter mentioned in paragraph 26F(3)(b) of the\nAct (carrying out customer due diligence in accordance with Part 2 of the Act). (2) The AML/CTF policies of the reporting entity must set out the circumstances in\nwhich the reporting entity will, for the purposes of undertaking initial customer\ndue diligence in accordance with section 28 of the Act:\n(a) collect kinds of KYC information relating to a customer; or\n(b) both collect and verify kinds of KYC information relating to a customer;\nincluding but not limited to the circumstances in which the reporting entity will\ncollect, or collect and verify, information on the customer's source of wealth and\nsource of funds."}], "evidence_b": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}, {"chunk_id": "c4024f4c4c1616cc::603::a3b7", "source_doc": "AMLR_Regulation_EU_2024-1624.pdf", "page": 68, "passage": "Article 37\nSpecific enhanced due diligence measures for cross-border correspondent relationships for crypto-asset service\nproviders\n1. By way of derogation from Article 36, with respect to cross-border correspondent relationships involving the\nexecution of crypto-asset services, with a respondent entity not established in the Union and providing similar services,\nincluding transfers of crypto-assets, crypto-asset service providers shall, in addition to the customer due diligence measures\nlaid down in Article 20, when entering into a business relationship, be required to:\n(a) determine if the respondent entity is licensed or registered;\n68/111 ELI: http://data.europa.eu/eli/reg/2024/1624/oj EN\n(b) gather sufficient information about the respondent entity to understand fully the nature of the respondent's business\nand to determine from publicly available information the reputation of the entity and the quality of supervision;\n(c) assess the respondent entity's AML/CFT controls;\n(d) obtain approval from senior management before establishing the new correspondent relationship;\n(e) document the respective responsibilities of each party to the correspondent relationship;\n(f) with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of,\nand performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity,\nand that it is able to provide relevant customer due diligence data to the correspondent entity, upon request."}], "rationale": "The AUSTRAC AML/CTF regime and the EU AMLR/TFR are parallel national/regional AML/CFT regimes implementing FATF standards. They apply to non-overlapping regulated populations (AUSTRAC-registered reporting entities vs EU obliged entities and CASPs). A firm operating in both jurisdictions complies with both independently. Although a labeller could imagine a transmission-of-information case where an AU reporting entity transfers personal data of a customer to an EU CASP — that case is GDPR/Privacy-Act territory, not an AU-AML vs EU-AML conflict. This pair is best characterised as an equivalence rather than a conflict and is so labelled in the equivalences file.", "would_conflict_if": ["Both regimes ever attempted extraterritorial assertion of the same VASP that produced contradictory obligations — current text scopes each to its jurisdiction's obliged entities."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:09b295d835af6b7e4f490286", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "d7502c011527b67c::3e7::ae26", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 13, "passage": "This Regulation shall not apply to a transfer of funds where any of the following conditions is met:\n(a) it involves the payer withdrawing cash from the payer's own payment account;\n(b) it constitutes a transfer of funds to a public authority as payment for taxes, fines or other levies within a Member\nState;\n(c) both the payer and the payee are payment service providers acting on their own behalf;\n(d) it is carried out through cheque images exchanges, including truncated cheques. This Regulation shall not apply to a transfer of crypto-assets where any of the following conditions is met:\n(a) both the originator and the beneficiary are crypto-asset service providers acting on their own behalf;\n(b) the transfer constitutes a person-to-person transfer of crypto-assets carried out without the involvement of a crypto-\nasset service provider. Electronic money tokens, as defined in Article 3(1), point (7), of Regulation (EU) 2023/1114, shall be treated as crypto-\nassets under this Regulation."}], "rationale": "AU_AML_CTF (Australian AML/CTF Act — AUSTRAC reporting entity framework) and EU_AMLR_TFR (EU AML regulation + Transfer of Funds Regulation 2023/1113). Both jurisdictions implement comparable AML/CFT obligations on regulated entities consistent with FATF standards. Entities operating across both face complementary (not contradictory) duties. The B passage notes specific EU TFR scope exclusions that don't conflict with the AU framework."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:00:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:96cbc3589d34bd7ce0ec073b", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "The EU_MICA_RTS passage (c51ad46265cea4e5::2f5::4513) discusses the notification obligations for financial entities providing crypto-asset services under MiCA. The SG_MAS_PRUDENTIAL_CRYPTO passage (7c04f2a0bd85290a::449::02f2) discusses the risk-based capital framework for Stablecoin Issuers (SCS) and the principle of 'same activities, same risk, same regulation'. The obligations are distinct: one concerns the notification of services to authorities, while the other concerns capital adequacy for issuers. There is no specific obligation in MiCA that pushes against the MAS prudential capital requirements for SCS issuers. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:40:59Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9739c50e311b9eb5aa67a7e3", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}], "rationale": "The AU_FEDREG_AML regime focuses on Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations, specifically regarding the identification of customers, reporting suspicious transactions, and the collection of information for electronic funds transfers (chunk cf7cefacba3f94bc::49a::f39e). The EU_PSD2 regime focuses on payment services, specifically the technical requirements for strong customer authentication and security measures for payment accounts (chunk adb1a81b9cecaf8c::64f::f5ad). While both regimes regulate electronic payments, they address distinct regulatory objectives: AML/CTF compliance versus payment security and authentication standards. There is no evidence in the provided passages of a direct obligation in one regime that conflicts with a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:29:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:4b661f299874a43ee3aa7648", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The evidence from Regime A (AU_ATO_CRYPTO) focuses on token mapping, tax compliance, and the crypto ecosystem in Australia (chunk_id e6bb47e92e88e16c::567::36c4). The evidence from Regime B (SG_FOUNDATIONAL_LEGISLATION) discusses MAS enforcement actions against ICO issuers and exchanges in Singapore, as well as the Payment Services Act (chunk_id b49627bb889ef1d9::3ef::7168). The passages describe distinct regulatory environments and enforcement actions in different jurisdictions (Australia vs. Singapore) and do not contain specific obligations that push against one another. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:52:54Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:3bce7865289eae5818ee72d0", "label": "non_conflict", "regime_a": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}, {"chunk_id": "25cbbd878a1b21d3::298::6f7d", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 43, "passage": "28. Third-country firms should be able to provide records tracking the relationship with the\nclient and, in particular, whether the client has taken the initiative to receive crypto asset\nservices with respect to a new product.\n\n5.4 When is a crypto-asset or a crypto-asset service of the same\ntype as another one (Guideline 4)\n\n29. The reverse solicitation regime leaves open the possibility for a third-country firm to\nmarket crypto-assets or crypto-asset services or activities of the same type in the context\nof the relationship started at the own exclusive initiative of a given client, subject to the\nthird-country firm also complying with Guideline 3 above."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}, {"chunk_id": "0e996ae99839f19e::3d0::2bb3", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "2020Ed. Act 2012 20\n(2) An organisation must not -\n(a) as a condition of providing a product or service, require an\nindividual to consent to the collection, use or disclosure of\npersonal data about the individual beyond what is\nreasonable to provide the product or service to that\nindividual; or\n(b) obtain or attempt to obtain consent for collecting, using or\ndisclosing personal data by providing false or misleading\ninformationwithrespecttothecollection,useordisclosure\nof the personal data, or using deceptive or misleading\npractices. (3) Anyconsentgiveninanyofthecircumstancesinsubsection(2)\nis not validly given for the purposes of this Act. (4) InthisAct,referencestoconsentgiven,ordeemedtohavebeen\ngiven, by an individual for the collection, use or disclosure of\npersonal data about the individual include consent given, or deemed\nto have been given, by any person validly acting on that individual's\nbehalf for the collection, use or disclosure of such personal data."}], "rationale": "The EU regime regulates the solicitation of clients by third-country crypto-asset firms (reverse solicitation) and the conditions under which they may market services. The SG PDPA regulates the collection, use, and disclosure of personal data, specifically focusing on the requirement for consent and the limitations on consent as a condition for service provision. The obligations in the EU regime concern the initiation of business relationships and marketing activities, whereas the SG PDPA obligations concern the privacy and data protection aspects of those relationships. There is no specific obligation in the EU regime that pushes against a specific obligation in the SG PDPA; rather, they regulate distinct aspects of a business relationship. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:41:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:950a6afb09470bfc8a791353", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "AU_PAYMENT_SYSTEMS", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_PAYMENT_SYSTEMS"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "0fc4f857c226f510::375::66b5", "source_doc": "Corporations_Act_2001_Vol1.pdf", "page": 296, "passage": "Part 1.6 Interaction with Australian Charities and Not-for-profits Commission Act Section 111L\nProvisions of this Act that do not apply to bodies corporate registered under the\nACNC Act\nItem Column 1 Column 2\nProvision(s) Topic\n2 section 138 ASIC may direct company to lodge\nconsolidated constitution\n3 section 139 Company must send copy of\nconstitution to member\n4 subsection 142(2), section 146 and Company must notify ASIC of\nsubsection 146A(2) changes of address\n5 (a) sections 180 to 183; and Duties of directors etc. (b) section 185, to the extent that it\nrelates to sections 180 to 183\n6 section 188, to the extent it relates to Responsibility of secretaries and\na provision mentioned in another directors for certain contraventions\nitem of this table\n7 sections 191 to 194 Interests of directors\n8 (a) sections 201L and 205A to 205C; Public information about directors\nand etc."}], "evidence_b": [{"chunk_id": "6644db515eb0e280::423::b3f1", "source_doc": "Payment_Services_Act_2019.pdf", "page": 22, "passage": "Powers of Authority to ensure interoperability between\npayment systems\n26.-(1) The Authority may, by written notice, direct a payment\nservice provider (being a major payment institution, an exempt\npayment service provider or a person exempt under section 100) that\noperates a payment system to adopt any common standard, on such\nterms and conditions as the Authority may consider appropriate, in\norder to ensure interoperability between different payment systems\noperated by different payment service providers. 2020Ed. Payment Services Act 2019 66\n(2) In considering whether to issue a written notice under\nsubsection (1), the Authority must have regard to the following\nmatters:\n(a) whether ensuring interoperability between different\npayment systems would be in the interests of the public;\n(b) theinterestsofeverypaymentserviceproviderthatwill be\ndirected to adopt the common standard;\n(c) theinterestsofpersonswho,inthefuture,mayberequired,\nor may desire, to adopt the common standard;\n(d) such other matters as the Authority may consider to be\nrelevant."}], "rationale": "The evidence for AU_CORPS_ACT (chunk 0fc4f857c226f510::375::66b5) outlines the interaction between the Corporations Act and the Australian Charities and Not-for-profits Commission Act, detailing specific provisions regarding company constitutions and director duties. The evidence for AU_PAYMENT_SYSTEMS (chunk 6644db515eb0e280::423::b3f1) concerns the Authority's powers to ensure interoperability between payment systems. The obligations in the Corporations Act relate to corporate governance and director responsibilities, while the obligations in the Payment Systems Act relate to technical infrastructure and interoperability. These are distinct regulatory domains with no apparent overlap or conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:6ab1b5a430c1a070439c27a9", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title V (CASP)"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "3a1785f95cb37b3c::336::8d0b", "source_doc": "AMLA_Regulation_EU_2024-1620.pdf", "page": 32, "passage": "The list of\nthe selected obliged entities shall be published by the Authority without undue delay upon completion of the selection\nprocess. The Authority shall commence direct supervision of the selected obliged entities six months after publication of\nthe list.\n5. Prior to the publication of the list of the selected obliged entities, the Authority shall inform the relevant\nnon-AML/CFT authorities of the outcomes of the process of assessment and classification of inherent and residual risk of\nthe obliged entities subject to assessment.\n6. A selected obliged entity shall remain subject to direct supervision by the Authority until the Authority commences\nthe direct supervision of selected obliged entities based on a list established for the subsequent selection period which no\nlonger includes that obliged entity."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::452::8eaf", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 63; or\n(b) a credit institution, central securities depository, investment firm, market operator, electronic money institution,\nUCITS management company, or an alternative investment fund manager that is allowed to provide crypto-asset\nservices pursuant to Article 60. EN\nL 150/114 2. Crypto-asset service providers authorised in accordance with Article 63 shall have a registered office in a Member\nState where they carry out at least part of their crypto-asset services. They shall have their place of effective management\nin the Union and at least one of the directors shall be resident in the Union.\n3. For the purposes of paragraph 1, point (a), other undertakings that are not legal persons shall only provide crypto-\nasset services if their legal form ensures a level of protection for third parties' interests equivalent to that afforded by\nlegal persons and if they are subject to equivalent prudential supervision appropriate to their legal form.\n4. Crypto-asset service providers authorised in accordance with Article 63 shall at all times meet the conditions for\ntheir authorisation.\n5."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLA Regulation establishing the AML supervisor and EU MiCA Title V crypto-asset service provider regime are designed to coexist — obligations apply cumulatively without collision. AMLA supervises CASPs as AMLR-obliged entities — aligned by design. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:8e1fad9c00ceb9d00765f52d", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}, {"chunk_id": "5d489619a0fb9ecf::14b::8e32", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": 31, "passage": "23 FATF (2013-2017), Anti-money laundering and terrorist financing measures and financial\ninclusion - With a supplement on customer due diligence, FATF, Paris www.fatf-\ngafi.org/media/fatf/content/images/Updated-2017-FATF-2013-Guidance.pdf\n\n30  GUIDANCE ON DIGITAL IDENTITY\nNon face-to-face business relationships and transactions"}], "rationale": "EU_PSD2 (Article 97 strong customer authentication for payment account access and electronic transactions) and FATF_R16 (FATF travel rule for VAs/VASPs — originator/beneficiary information for transfers). Both broadly relate to payments/transfers but address different specific concerns — PSD2 is about authenticating the payer at account access/transaction-initiation; FATF R16 is about identifying parties in cross-border VA transfers. The cited passages don't impose conflicting obligations on the same action."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:37:16Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9cdefba3888eea049ed8b3f6", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::58c::2a32", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 32, "passage": "The competent authorities shall grant an authorisation only if, taking into account the need to ensure the sound\nand prudent management of a payment institution, the payment institution has robust governance arrangements for its\npayment services business, which include a clear organisational structure with well-defined, transparent and consistent 23.12.2015 EN Official Journal of the European Union L 337/67\nlines of responsibility, effective procedures to identify, manage, monitor and report the risks to which it is or might be\nexposed, and adequate internal control mechanisms, including sound administrative and accounting procedures; those\narrangements, procedures and mechanisms shall be comprehensive and proportionate to the nature, scale and complexity\nof the payment services provided by the payment institution.\n5. Where a payment institution provides any of the payment services as referred to in points (1) to (7) of Annex I and,\nat the same time, is engaged in other business activities, the competent authorities may require the establishment of a\nseparate entity for the payment services business, where the non-payment services activities of the payment institution\nimpair or are likely to impair either the financial soundness of the payment institution or the ability of the competent\nauthorities to monitor the payment institution's compliance with all obligations laid down by this Directive.\n6."}], "rationale": "The evidence for AU_APRA_CPS230 focuses on operational risk management, resilience, and the management of service providers (chunk_ids f296a7e0bead93df::4a5::9828 and 4b6fab404e7acfca::3d7::737c). The evidence for EU_PSD2 focuses on strong customer authentication, security credentials, and governance for payment institutions (chunk_ids adb1a81b9cecaf8c::64f::f5ad and adb1a81b9cecaf8c::58c::2a32). While both regimes require robust governance and internal controls, the specific obligations—operational resilience and service provider risk management under APRA versus strong customer authentication and security credential protection under PSD2—regulate distinct aspects of a financial institution's operations. There is no specific obligation in one regime that directly contradicts or invalidates a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:20f733c9401e560d8fa9bb21", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "0fc4f857c226f510::375::66b5", "source_doc": "Corporations_Act_2001_Vol1.pdf", "page": 296, "passage": "Part 1.6 Interaction with Australian Charities and Not-for-profits Commission Act Section 111L\nProvisions of this Act that do not apply to bodies corporate registered under the\nACNC Act\nItem Column 1 Column 2\nProvision(s) Topic\n2 section 138 ASIC may direct company to lodge\nconsolidated constitution\n3 section 139 Company must send copy of\nconstitution to member\n4 subsection 142(2), section 146 and Company must notify ASIC of\nsubsection 146A(2) changes of address\n5 (a) sections 180 to 183; and Duties of directors etc. (b) section 185, to the extent that it\nrelates to sections 180 to 183\n6 section 188, to the extent it relates to Responsibility of secretaries and\na provision mentioned in another directors for certain contraventions\nitem of this table\n7 sections 191 to 194 Interests of directors\n8 (a) sections 201L and 205A to 205C; Public information about directors\nand etc."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}], "rationale": "AU_CORPS_ACT (Australia's Corporations Act 2001 — broad corporate-law framework including financial-services regulation) and EU_MAR (EU Market Abuse Regulation 596/2014 — insider dealing, market manipulation, and information-disclosure framework). Both regulate market conduct and corporate behaviour in their jurisdictions but with different specific obligations — AU Corps Act is broad corporate law, EU MAR is specifically market-abuse-focused. Distinct jurisdictional perimeters; no direct obligation conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:bd1d424ae60e014b7e4ae778", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::15a::fbf2", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 80, "passage": "Article 63\nCooperation with AMLA\nFIU and supervisory authorities shall cooperate with AMLA and shall provide it with all the information necessary to allow\nit to carry out its duties under this Directive and under Regulations (EU) 2024/1624 and (EU) 2024/1620.\nSECTION 2\nCooperation with other authorities and exchange of confidential information"}, {"chunk_id": "df546f2364aaf9e2::620::328c", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 79, "passage": "Article 62\nCommunication of the list of the competent authorities\n1. In order to facilitate and promote effective cooperation, and in particular the exchange of information, Member States\nshall communicate to the Commission and AMLA:\n(a) the list of supervisors responsible for overseeing the compliance of the obliged entities with Regulation (EU)\n2024/1624, as well as, where relevant, name of the public authority overseeing self-regulatory bodies in their\nperformance of supervisory functions under this Directive, and their contact details;\n(b) the contact details of their FIU;\n(c) the list of other competent national authorities.\n2. For the purposes of paragraph 1, the following contact details shall be provided:\n(a) a contact point or, failing that, the name and role of a contact person;\n(b) the email and phone number of the contact point or, failing that, the professional email address and phone number of\nthe contact person.\nELI: http://data.europa.eu/eli/dir/2024/1640/oj 79/94\n\nEN\n3. Member States shall ensure that the information provided to the Commission and AMLA pursuant to paragraph 1 is\nupdated as soon as a change takes place.\n4. AMLA shall publish a register of the authorities referred to in paragraph 1 on its website and facilitate the exchange of\ninformation referred to in paragraph 2 between competent authorities. The authorities in the register shall, within the scope\nof their powers, serve as a contact point for the counterpart competent authorities. FIUs and supervisory authorities shall\nalso serve as a contact point for AMLA."}, {"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "75b61beed88910f9::4ad::debc", "source_doc": "National_ML_TF_Risk_Assessment.pdf.coredownload.inline.pdf", "page": null, "passage": "The guidance contained in this document takes into consideration previous FATF work , which is still valid reference material. The general\nprinciples contained in this paper are also relevant when conducting risk assessments of a more\nfocussed scope, such as in assessments of a particular financial or DNFBP sector (for example, the\nsecurities sector) or of thematic issues (for example, the proceeds of corruption related ML). All of\nthese types of assessments (comprehensive, sectoral or thematic) carried out at the national level\nmay also form the basis for determining whether to apply enhanced or specific measures, simplified\nmeasures, or exemptions from AML/CFT requirements. Furthermore, while FATF\nRecommendation 1 does not create specific risk assessment obligations regarding the financing of\nproliferation of weapons of mass destruction, the general principles laid out in this guidance could\nalso be used in conducting a risk assessment for this area.\n3. The guidance in this document is not intended to explain how supervisors should assess risks\nin the context of risk-based supervision, although risk-based supervision will likely be informed by a\nnational-level risk assessment."}, {"chunk_id": "1393876621ff1b2d::215::b185", "source_doc": "Guidance-Criminalising-Terrorist-Financing.pdf.coredownload.inline.pdf", "page": 3, "passage": "4. This guidance is based on the same general principles that govern both the interpretation and\nassessment of the FATF standards. As noted in the introduction to the 2012 FATF\n\"Countries have diverse legal, administrative and operational frameworks and different\nRecommendations:\nfinancial systems, and so cannot all take identical measures to counter these threats. The FATF\nRecommendations, therefore, set an international standard, which countries should implement\nthrough measures adapted to their particular circumstances.\"\nhow"}], "rationale": "EU_AMLA (EU's new AML Authority under AMLD6 — supervisory cooperation framework) and INT_FATF_GENERAL (FATF general AML/CFT standards). The EU AMLA framework is the EU's institutional implementation of FATF AML/CFT standards; cooperation between AMLA, national FIUs, and international AML bodies is explicitly contemplated. Aligned by design — EU implements FATF."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:d31b7c82b5aa1bb3147bdf7e", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiFID II"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::49c::69f4", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 53, "passage": "Member States shall require that investment firms and market operators operating an MTF or an OTF establish,\npublish and maintain and implement transparent and non-discriminatory rules, based on objective criteria, governing\naccess to its facility.\n4. Member States shall require that investment firms and market operators operating an MTF or an OTF have\narrangements to identify clearly and manage the potential adverse consequences for the operation of the MTF or OTF,\nor for the members or participants and users, of any conflict of interest between the interest of the MTF, the OTF, their\nowners or the investment firm or market operator operating the MTF or OTF and the sound functioning of the MTF or\nOTF.\n5. Member States shall require that investment firms and market operators operating an MTF or OTF comply with\nArticles 48 and 49 and have in place all the necessary effective systems, procedures and arrangements to do so.\n6. Member States shall require that investment firms and market operators operating an MTF or an OTF clearly inform\nits members or participants of their respective responsibilities for the settlement of the transactions executed in that\nfacility."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLD 6 AML supervisory directive and EU MiFID II investment-firm conduct directive are designed to coexist — obligations apply cumulatively without collision. Investment firms are AMLR/AMLD6 obliged entities — supervisory regime applies cumulatively with MiFID II. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:fa810c01430ebe253028bd3c", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}], "rationale": "AU_FEDREG_AML (Australian AML/CTF Act and Rules) and FATF_R16 (FATF Recommendation 16 — travel rule). Australia is implementing FATF R16 standards through the AML/CTF framework (currently consulting on full DCE travel-rule extension). Aligned direction."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:39:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:a0ce6adf45cb1efe7376b303", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "rationale": "The obligations in Prudential Standard CPS 230 (Regime A) focus on operational risk management, resilience, and the management of service providers to ensure critical operations continue through disruptions. In contrast, the EU DAC8 Directive (Regime B) regulates the reporting and exchange of information regarding crypto-asset users to tax authorities. The passages confirm that these regimes regulate distinct domains: one governs operational resilience and risk management for APRA-regulated entities, while the other establishes tax transparency rules for crypto-asset operators. There is no specific obligation in CPS 230 that pushes against a specific obligation in DAC8, nor is there evidence of overlap in their application."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:47:52Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:9d951c80ca408d8acbbb3c96", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::4f1::4905", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "Treasury received substantial feedback\nfrom a range of stakeholders with industry-wide support for clarity on the regulatory settings for crypto\nassets. In particular, key stakeholders flagged the need to prioritise the 'token mapping' work, which\ninvolves reviewing a range of crypto assets to identify how they fit within the existing regulatory framework. Accordingly, to commence the reform agenda, I will prioritise the complex 'token mapping' work in 2022. Token mapping is a foundational piece of work to support Government to identify how crypto assets and\nrelated services ought to be regulated. It will also importantly aid the development of a licensing framework\nby assisting in demarcating the perimeter between financial product crypto assets (already the subject of\nfinancial services laws) and non-financial product crypto assets (that may warrant a separate crypto asset\nregulatory framework). Parliament House Canberra ACT 2600 Australia\nOFFICIAL: Sensitive OFFICIAL: Sensitive Subject to your agreement, I propose to announce the reform agenda, commence stakeholder consultations\nand release a public consultation paper on token mapping in 2022 (as indicated in Treasury's earlier\nconsultation paper on crypto licensing and custody requirements)."}, {"chunk_id": "e6bb47e92e88e16c::37a::29f6", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 12, "passage": "16. After token mapping, licensing and custody reforms are the logical next step for crypto reforms\nin Australia. The identification of appropriate obligations and operational standards for crypto\nasset service providers and how they safe-keep assets for customers is a key step for consumer\nprotection; ensuring consumers do not lose assets to avoidable business failure or misuse of\nassets by the provider.\n\n17. The Government will release a consultation paper proposing a licensing and custody framework\nfor crypto asset service providers in mid-2023 to allow for sufficient consultation prior to the\nintroduction of legislation. The paper will reflect ongoing work and consultation in this area and\nleverage the findings from the token mapping exercise. The responses to the following\nquestions will help inform the general direction of future policy and potential consumer\nprotections."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::284::b4a8", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 38, "passage": "94. The FATF Standards, including the definitions of virtual assets and VASPs, represent\na minimum standard for countries to introduce. In line with the RBA, countries may\nchoose to extend their AML/CFT regimes to include other digital assets and entities,\nbeyond the FATF definition of virtual asset and VASP. Such a determination should\nbe made on the basis of a ML/TF risk assessment, with consideration of the\nchallenges associated with regulatory divergence.\n\nUPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS  37\nPART THREE:\nAPPLICATION OF FATF STANDARDS TO COUNTRIES AND\nCOMPETENT AUTHORITIES"}], "rationale": "The AU_TREASURY_DAP passages describe a domestic policy agenda focused on 'token mapping' and the development of a future licensing framework for crypto asset service providers (chunk_ids d75262e404517e0c::4f1::4905, e6bb47e92e88e16c::37a::29f6). The INT_FATF_VASP passages define the scope of the FATF Standards regarding Virtual Asset Service Providers (VASPs) and note that countries may choose to extend their regimes beyond the minimum standard (chunk_ids 85240528438654b9::1cd::07d7, 85240528438654b9::284::b4a8). The FATF text explicitly states that countries may extend their AML/CFT regimes to include other digital assets and entities beyond the FATF definition of VASP, which aligns with the Australian government's intent to develop a specific regulatory framework. There is no evidence of a specific obligation in one regime that directly contradicts or invalidates the other; rather, the FATF provides a minimum global standard that Australia intends to implement and potentially expand upon through its domestic reforms."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:01:31Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:31967d6b7f98b1a01513e9d3", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "rationale": "The EU MICA Title IV EMT passages regulate the disclosure obligations of issuers of e-money tokens, specifically regarding the content and notification of crypto-asset white papers and liability for misleading information (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e). The INT Basel General passages regulate the accounting treatment of fiduciary assets and the calculation of regulatory capital, including leverage ratio exposure measures and expected losses (chunk_id 32afd37cade34f84::34b::8d30). The obligations in the EU regime relate to consumer disclosure and issuer liability, while the obligations in the Basel regime relate to banking supervision and capital adequacy. These are distinct regulatory domains with no apparent overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:33:48Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f6464a5f666affa875db841a", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLD6"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "evidence_b": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}], "rationale": "The EU AMLD6 passage (chunk 85307f9e2a040982::14a::134d) discusses the scope of Directive (EU) 2022/2556 regarding digital operational resilience for the financial sector. The MAS TRM passage (chunk 20d526d712753652::403::be97) discusses internal processes for inaccurate representations and the application of guidelines (including TRM Guidelines) to licensees. The obligations in the EU passage relate to sector-wide digital operational resilience, while the MAS passage relates to customer communication regarding inaccuracies and the application of principles-based guidelines. These are distinct regulatory domains with no apparent overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:7c9a633a5b22d8a3659f0806", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU Travel Rule (IFTI)"}, "regime_b": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU TTR Threshold"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "561fc09c315f8349::45d::68bb", "source_doc": "Money transferred to and from overseas International funds transfer instruction (IFTI) reports.pdf", "page": null, "passage": "In\nan IFTI-E: e the transfer instruction is carried out or passed on electronically https://www.austrac.gov.au/business/core-guidance/reporting/money-transferred-and-overseas-international-funds-transfer-instruction-ifti-reports 2/6 25/06/2025, 23:15 Money transferred to and from overseas: International funds transfer instruction (IFTI) reports | AUSTRAC e the transfer is within the same financial institution or between financial\ninstitutions, such as banks, building societies or credit unions. An IFTI-E can be either:\ne outgoing - the ordering institution accepts the instruction in Australia and transfers money to the payee via a beneficiary institution overseas e incoming - the ordering institution accepts the instruction overseas and\ntransfers money via a beneficiary institution in Australia. Information required in IFTI-E reports\nIFTI-E reports must include details about everyone involved in the transfer:\ne the payer - the business, organisation or individual who instructs the ordering\ninstitution to transfer money\ne the ordering institution - the institution that accepts the transfer instruction"}], "evidence_b": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): AUSTRAC IFTI / EFTI travel-rule reporting and AUSTRAC TTR $10k cash threshold reporting are designed to coexist — obligations apply cumulatively without collision. Both reporting components of the AUSTRAC AML/CTF regime — different obligations but same statutory parent. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:bf9214e6c8778424d9e3aa68", "label": "conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "rationale": "AU_FEDREG_AML (Australian AML/CTF statutory regime — reporting entity obligations including KYC information collection and cross-border movement reporting) and EU_GDPR (GDPR cross-border data transfer principles, processing of personal data in compliance with Directive 95/46/EC successor framework). When AU reporting entities have EU-resident customers, the data collection and transmission required by AML/CTF engages GDPR's cross-border transfer restrictions. Operationally resolvable via GDPR Art. 6(1)(c) plus Chapter V instruments. Same conflict shape as the labelled cross-jurisdictional AML ↔ GDPR pattern.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:45Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:34:05Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:bc7e9581ede654add5569e42", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLD6"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "rationale": "The evidence for AU_ATO_CRYPTO focuses on token mapping, tax compliance, and the crypto ecosystem in Australia (chunk e6bb47e92e88e16c::567::36c4). The evidence for EU_AMLD6 references Directive (EU) 2022/2556 regarding digital operational resilience for the financial sector (chunk 85307f9e2a040982::14a::134d). The two regimes regulate distinct domains: Australian tax and crypto regulation versus EU financial sector operational resilience. There is no evidence of a specific obligation in one regime conflicting with a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:01:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:04589ff2cb2234d57643a42c", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "08b3db1cc7362f25::3bb::5dba", "source_doc": "Guidance-Correspondent-Banking-Services.pdf.coredownload.pdf", "page": null, "passage": "FATF GUIDANCE\nCORRESPONDENT\nBANKING SERVICES\nOCTOBER 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on correspondent banking services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/correspondent-banking-services.html\n© 2016 FATF/OECD."}], "rationale": "The EU_EMD2 passages describe the regulatory framework for digital operational resilience in the financial sector (Directive 2022/2556 and Regulation 2022/2554). The INT_FATF_GENERAL passages describe the general principles and standards for Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT), including risk assessment methodologies and specific reporting requirements like CTRs and STRs. The obligations in the EU_EMD2 regime (operational resilience, recovery plans) are distinct from the obligations in the INT_FATF regime (AML/CFT risk assessment, reporting). There is no specific obligation in the EU_EMD2 text that conflicts with a specific obligation in the INT_FATF text; rather, they regulate different domains of financial stability and compliance."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:729da4bedb8434c1ac89d79a", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "regime_b": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLD 6 AML supervisory directive and EU DORA ICT operational-resilience regulation operate in disjoint regulatory domains at the obligation level. AML supervision vs ICT operational resilience — disjoint subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:11:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:2c83e8a79d1dc3d091537e2f", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "The EU_EMD2 passage discusses the Digital Operational Resilience Act (DORA) and financial rules for the European Authority (chunk 85307f9e2a040982::14a::134d). The SG_MAS_PRUDENTIAL_CRYPTO passage discusses the 'Prudential Treatment & Disclosures of Cryptoasset Exposures' and the 'same activities, same risk, same regulation' principle for Stablecoin Issuers (chunk 7c04f2a0bd85290a::449::02f2). The obligations regarding operational resilience and financial rules in the EU regime do not directly oppose the prudential capital requirements for cryptoasset exposures in the Singapore regime. The regimes regulate different aspects of financial stability (operational resilience vs. prudential capital treatment) and reinforce the need for a robust framework rather than conflicting with one another."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:40:37Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:3eff9c5828172362168a8f6d", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "c0300673081f7232::294::7f91", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 1, "passage": "(6) Member States have put in place rules and guidance, which differ from Member State to Member State, to tax income\nderived from crypto-asset transactions. However, the decentralised nature of crypto-assets makes it difficult for\nMember States' tax administrations to ensure tax compliance.\n\n(1) Opinion of 13 September 2023 (not yet published in the Official Journal).\n\n(2) Opinion of 23 March 2023 (OJ C 184, 25.5.2023, p. 55).\n\n(3) Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing\nDirective 77/799/EEC (OJ L 64, 11.3.2011, p. 1).\nELI: http://data.europa.eu/eli/dir/2023/2226/oj 1/38\n\nEN"}], "rationale": "The AU_TREASURY_DAP passages discuss the Australian government's 'token mapping' exercise to identify how crypto assets fit within the financial services framework and the subsequent development of licensing and custody reforms (chunk_ids: d75262e404517e0c::47b::7c9f, e6bb47e92e88e16c::37a::29f6). In contrast, the EU_DAC8 passages focus on the reporting and exchange of information obligations for crypto-asset service providers to tax administrations to combat tax evasion (chunk_ids: c0300673081f7232::294::7f91, c0300673081f7232::3d8::ddf3). The obligations in the EU regime relate to tax reporting and administrative cooperation, whereas the Australian regime addresses the classification and licensing of crypto assets and service providers. These are distinct regulatory domains with no apparent specific obligation in one regime pushing against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:04:40Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:4de5af9e2f7116c186f55d67", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4a92930a8caf822::380::0a18", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 12, "passage": "Part 1 Preliminary\nSection 1-4\n(a) in relation to registration or proposed registration of a person under Part 6\nof the Act as a remittance network provider-registrable remittance\nnetwork services; or\n(b) in relation to registration or proposed registration of a person under Part 6\nof the Act as an independent remittance dealer or a remittance affiliate of a\nregistered remittance network provider-registrable remittance services; or\n(c) in relation to registration or proposed registration of a person under Part 6A\nof the Act as a virtual asset service provider-registrable virtual asset\nservices.\nrelated body corporate has the same meaning as in the Corporations Act 2001.\nsuper-agent has the meaning given by subsection 4-13(2).\ntracing information, in relation to a transfer of value, means information that\nsatisfies both of the following:\n(a) the information:\n(i) for a transfer from an"}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}, {"chunk_id": "c51ad46265cea4e5::462::80d8", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 76, "passage": "6.5 Annex V - Draft RTS pursuant to Article 62(5) of MiCA\nCOMMISSION DELEGATED REGULATION (EU) .../...\nof XXX\nsupplementing Regulation (EU) 2023/1114 of the European Parliament and of the\nCouncil with regard to regulatory technical standards specifying the information to be\nincluded in an application for authorisation as crypto-asset service provider\n(Text with EEA relevance)\nTHE EUROPEAN COMMISSION,\nHaving regard to the Treaty on the Functioning of the European Union,\nHaving regard to Regulation (EU) 2023/1114 of the European Parliament and of the Council\nof 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2012\nand (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/193718, and in particular\nArticle 62(5), third subparagraph, thereof,\nWhereas:\n(1) The information to be provided in an application for authorisation as crypto-asset service\nprovider should be sufficiently detailed and comprehensive to enable competent\nauthorities to assess whether an applicant meets the applicable requirements laid down\nin Title V and, where relevant, Title VI of Regulation (EU) 2023/1114."}], "rationale": "The AU_TRAVEL_RULE passages discuss the Australian regulatory framework for remittance networks and virtual asset service providers, including the status of the FATF 'Travel Rule' for digital currency exchanges (c4a92930a8caf822::380::0a18, 30a32a386d15ba2b::4f3::edc3). The EU_MICA passages describe the European legal framework for crypto-asset service providers, including the provision of advice on crypto-assets and the requirements for authorisation (f9082873c5d9ba9d::302::bbe0, c51ad46265cea4e5::462::80d8). The obligations and regulatory scopes are distinct: one focuses on Australian remittance and virtual asset registration, while the other outlines European MiCA requirements for crypto-asset service provision. There is no specific obligation in one regime that pushes against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:12ebdf5a960cdc930d2bbe3f", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "SG_MAS_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "a82833dc0f7ca903::17a::c743", "source_doc": "Outsourcing_Guidelines_2018.pdf", "page": 3, "passage": "1.2 These Guidelines1 on Outsourcing (\"Guidelines\") set out the Monetary Authority of\nSingapore's (\"MAS\") expectations of an institution that has entered into any outsourcing\narrangement or is planning to outsource its business activities2 to a service provider. An\ninstitution should conduct a self-assessment of all existing outsourcing arrangements against\nthese Guidelines3."}], "rationale": "AU_APRA_CPS234 (APRA's Information Security prudential standard — CPS 234 / CPG 230 operational risk context) and SG_MAS_OUTSOURCING (MAS Outsourcing Guidelines for material outsourcing arrangements). Both touch on operational-risk / third-party concerns but address different specific obligations — CPS 234 is information-security; MAS Outsourcing is supervision of outsourced business activities. Distinct mechanisms."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:3d353da4aeabd77c88ade55b", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "75b61beed88910f9::4ad::debc", "source_doc": "National_ML_TF_Risk_Assessment.pdf.coredownload.inline.pdf", "page": null, "passage": "The guidance contained in this document takes into consideration previous FATF work , which is still valid reference material. The general\nprinciples contained in this paper are also relevant when conducting risk assessments of a more\nfocussed scope, such as in assessments of a particular financial or DNFBP sector (for example, the\nsecurities sector) or of thematic issues (for example, the proceeds of corruption related ML). All of\nthese types of assessments (comprehensive, sectoral or thematic) carried out at the national level\nmay also form the basis for determining whether to apply enhanced or specific measures, simplified\nmeasures, or exemptions from AML/CFT requirements. Furthermore, while FATF\nRecommendation 1 does not create specific risk assessment obligations regarding the financing of\nproliferation of weapons of mass destruction, the general principles laid out in this guidance could\nalso be used in conducting a risk assessment for this area.\n3. The guidance in this document is not intended to explain how supervisors should assess risks\nin the context of risk-based supervision, although risk-based supervision will likely be informed by a\nnational-level risk assessment."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}, {"chunk_id": "018117ef1e757630::428::d321", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Strengthening AML/CFT Controls of\nDigital Payment Token Service Providers\nMarch 2021 Introduction\nThis infographic sets out recent international developments and MAS' supervisory expectations on\nAML/CFT controls for the Digital Payment Token (DPT) sector.\n• This infographic is intended to raise industry awareness to the money laundering and terrorism financing (ML/TF)\nrisks in the DPT sector, and provide additional supervisory information to help DPT service providers implement\neffective policies, procedures and controls to deal with the ML/TF risks.\n• In particular, this infographic focuses on:\nI) Financial Action Task Force (FATF) Standards and recent developments;\nII) ML/TF Risks in DPT sector; and\nIII) Overview of MAS' AML/CFT requirements and expectations for the DPT sector - including key AML/CFT\nconsiderations relating to new DPT products, enhanced customer due diligence (ECDD) and value transfer.\n• The infographic supplements existing AML/CFT requirements, and should be read in conjunction with the Notice\nPS-N02 and accompanying Guidelines."}], "rationale": "INT_FATF_GENERAL (FATF general AML/CFT standards — risk-based approach) and SG_AML (MAS Notice 314 AML/CFT framework for life insurers + DPT-specific AML controls). Singapore's AML framework implements FATF standards through MAS notices. Reinforcing relationship."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T06:30:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.72, "record_type": "conflict", "pair_id": "conflict:d108c129033142c42738809d", "label": "conflict", "regime_a": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "SG PSA DPT (PSN02)"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG MAS Stablecoin"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "evidence_a": [{"chunk_id": "61149885d6ded889::444::2957", "source_doc": "MAS_Notice_824_FinanceCompanies_2025-06-30.pdf", "page": 2, "passage": "(a) a digital payment token service;\n(b) a digital payment token transfer service;\n(c) a custodian wallet service;\n\"STR\" means suspicious transaction report;\n\"STRO\" means the Suspicious Transaction Reporting Office, Commercial Affairs\nDepartment of the Singapore Police Force;\n\"trust relevant party\" has the same meaning as defined in paragraph 2.1 of MAS Notice\nTCA-N03;\n\"TSOFA\" means the Terrorism (Suppression of Financing) Act 2002;\n\"value transfer\" refers to any transaction carried out on behalf of a value transfer originator\nthrough a financial institution with a view to making one or more digital tokens available\nto a beneficiary person at a beneficiary institution, irrespective of whether the originator\nand the beneficiary are the same person; and\n\"wire transfer\" refers to any transaction carried out on behalf of a wire transfer originator\nthrough a financial institution by electronic means with a view to making an amount of\nfunds available to a beneficiary person at a beneficiary institution, irrespective of whether\nthe originator and the beneficiary are the same person."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::40b::3ddb", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 37, "passage": "15 August 2023 | 46\nWe believe that the proposed changes are sufficient. Under the current Payment Services\nAct 2019 (\"PS Act\") framework, stablecoins are treated as DPTs. In accordance with the\ncurrent scope of the PS Act, entities that deal in and/or facilitate the exchange of\nstablecoins therefore fall within the scope of regulated DPT services. However, stablecoin issuers are presently not regulated in terms of ensuring the value\nstability of stablecoins. Accordingly, the \"Stablecoin Issuance Service\" will regulate entities\nbased in Singapore that perform the function of controlling the total supply, minting and\nburning of a SCS. Such an SCS will be labelled using a specific term, such as \"regulated\nstablecoin\", \"qualifying stablecoin\" or \"securely-backed stablecoin\". This is well balanced\nwith the PS Act as activities relating to other types of stablecoins, including algorithmic,\ncommodity-backed, multi-currency and other types of stablecoins, will continue to be\nsubject to the existing DPT regime under the PS Act."}, {"chunk_id": "7c04f2a0bd85290a::4a8::5038", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "The Stable coins (SCS) targeted/offered/sold/ exchange to Singapore residents and\nbusinesses in\n2. Any settlement /obligation/contracts for such entities or related group either have SG\nas arbitration or under courts of Singapore\n3. When such overseas issued Stablecoins in circulation with Singapore residents exceed a\nrisk threshold of say, S$3M or equivalent / month and particularly those which are\nconsidered as designated payment system overseas. Question 2. MAS seeks comments on whether it is sufficient to introduce an additional regulated\npayment service of stablecoin issuance, and whether there is a need to introduce any\nother regulated services specific to stablecoins. ANZ suggests the additional regulation in PS to cover all aspects of Issuance, distribution,\ncirculation, and accessibility, including provision of custodial services for SCS with suitable\namount caps and withdrawal /exchange into pegged currency locally. Question 3. MAS seeks comments on whether the regulatory approach for bank and non-bank SCS\nissuers is appropriate and achieves an equivalent regulatory outcome for SCS issued in\nSingapore to be able to maintain a high degree of value stability of SCS."}, {"chunk_id": "474e6158f6621389::16c::cf83", "source_doc": "2023_Response_DPT_CP_Part2.pdf", "page": 7, "passage": "23 November 2023 | 7\nrisk of DPTSPs setting up in Singapore with the intent to primarily serve foreign retail customers who\nare not subject to MAS' consumer access measures. DPTSPs regulated in Singapore should therefore\napply the consumer access measures to all retail customers when offering DPT services.\nTreatment of DPT Holdings for Determining AI Eligibility"}], "rationale": "MAS's stablecoin framework (2022 CP; 2023 Response) explicitly states that, under the current Payment Services Act 2019 framework, stablecoins are treated as DPTs and entities dealing in or facilitating exchange of stablecoins fall within the PS Act DPT service regime (Annex Submissions §4.23). Whether a particular foreign stablecoin offering triggers MAS DPT obligations turns on fact-sensitive questions: does the issuer actively offer to Singapore residents? Does any SG arbitration or governing-law clause attach? Are settlement obligations directed into Singapore? (See industry submission 2023 Annex raising precisely these questions.) Two issuers with identical legal entities can reach opposite conclusions on PS Act scope depending on jurisdictional touchpoint facts.", "compliant_paths": ["Document marketing geography and customer-acquisition channels; restrict explicit Singapore-resident onboarding if seeking to remain outside the PS Act DPT regime."], "out_of_scope_assumptions": ["Issuer is non-MAS-regulated and operating from offshore."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:17:16Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:1293f9fe73b5e0d3431a2868", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "ba862e1f095bceac::1a6::1f0e", "source_doc": "FATF Recommendations 2012.pdf.coredownload.inline.pdf", "page": 79, "passage": "4. A country need not impose a separate licensing or registration system with respect to natural\nor legal persons already licensed or registered as financial institutions (as defined by the FATF\nRecommendations) within that country, which, under such license or registration, are\npermitted to perform VASP activities and which are already subject to the full range of\napplicable obligations under the FATF Recommendations."}], "rationale": "The EU_MAR passages regulate market abuse, insider dealing, and market manipulation within financial markets (chunk_ids 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The INT_FATF_VASP passages regulate Anti-Money Laundering/CFT obligations for Virtual Asset Service Providers (VASPs) and Virtual Assets (chunk_ids 85240528438654b9::1cd::07d7, ba862e1f095bceac::1a6::1f0e). While a VASP may be subject to both regimes, the obligations are distinct: MAR focuses on market integrity and preventing manipulation, whereas FATF focuses on AML/CFT compliance. The passages do not describe a specific obligation in one regime that directly contradicts or invalidates an obligation in the other. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:4c257507afa040fc55b27f0d", "label": "conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "rationale": "AU_TTR_THRESHOLD (AUSTRAC threshold-transaction reports of AUD 10,000+ — AML data disclosure obligation) and EU_GDPR (Article 44+ restricting transfer of personal data to third countries). When an AU reporting entity has EU-resident customers and must report their transaction details to AUSTRAC, this constitutes a cross-border data transfer from the EU; GDPR Chapter V conditions apply. The tension is real but operationally resolvable via GDPR Article 6(1)(c) ('legal obligation' lawful basis) plus an appropriate Chapter V transfer mechanism (e.g. SCCs or derogation under Art. 49(1)(d) for important reasons of public interest). Severity low because the EU-data overlap is narrow (most TTRs concern AU-resident transactions) and the resolution path is well-established. Same shape as the labelled EU TFR ↔ GDPR conflict in the careful cohort, scaled down to the threshold-reporting subset.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:23:17Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.62, "record_type": "non_conflict", "pair_id": "non_conflict:7fdafa66029d240e94274b2c", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AML/CTF Act + Rules"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "FATF", "short_name": "FATF Recommendation 16 (Travel Rule)"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}, {"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}], "evidence_b": [{"chunk_id": "85240528438654b9::207::feef", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline (1).pdf", "page": 58, "passage": "178. As set out in INR. 15, countries should apply Recommendation 16 to VA transfers\nand VASPs. Countries should apply Recommendation 16 regardless of whether the\nvalue of the traditional wire transfer or the VA transfer is denominated in fiat\ncurrency or a VA. However, recognising the unique technological properties of VAs,\nRecommendation 16 applies in an amended way to VAs as set out in paragraph 7(b)\nof INR.15. The application of the FATF's wire transfer requirements in the VA\ncontext is called the travel rule."}, {"chunk_id": "85240528438654b9::525::439a", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline (1).pdf", "page": 66, "passage": "201. Given the 'sunrise issue' in relation to the travel rule, countries should adopt a RBA\nin the assessment of the business models presented by VASPs. Countries should\nconsider the full context of travel rule compliance, including whether there are\nsufficient risk mitigation measures taken by the VASP to adequately manage the\nattendant ML/TF risks. Regardless of the regulation in a certain country, a VASP\nmay implement robust control measures to comply with the travel rule\nrequirements. Examples include VASPs restricting VA transfers to within their\ncustomer base (i.e., internal transfers of VAs within the same VASP), only allowing\nconfirmed first-party transfers outside of their customer base (i.e., the originator\nand the beneficiary are confirmed to be the same person) and enhanced monitoring\nof transactions. See Section IV \"Counterparty VASP Identification and Due\nDiligence\" for more risk remediation examples. While the introduction and\nimplementation of relevant regulations by countries is important in itself, the\nabsence of relevant regulations in one country does not necessarily preclude the\neffectiveness of measures introduced by a VASP on its own.\n\nUPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS  65\nVA transfers to/from 'intermediary VASPs'"}], "rationale": "AUSTRAC's AML/CTF regime broadly aligns with FATF standards (Australia is a FATF member and AUSTRAC's customer-identification, record-keeping and reporting obligations implement R.10–R.21 in substance). On Recommendation 16 specifically the alignment is currently partial: the AUSTRAC NRA explicitly notes that Australia's DCE regime applies only to digital-currency↔fiat exchanges and that the FATF Travel Rule has not yet been implemented for digital-currency exchanges. This is an implementation gap rather than a legal conflict — FATF Recommendation 16 is non-binding and FATF itself anticipates a 'sunrise' transition period (FATF VA/VASP guidance ¶201). The rubric resolves to No (no specific binding AU obligation pushes against any specific FATF expectation; the FATF expectation is that AU will close the gap). It is flagged borderline.", "would_conflict_if": ["FATF rated Australia non-compliant on R.16 and AUSTRAC's primary law explicitly carved out crypto-to-crypto VASPs in a way that could not be remedied by rule-making.", "The pair were narrowed to 'AUSTRAC current binding rules' vs 'FATF immediate-effect expectation' — there the friction is real but still not a structural conflict."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:7fdafa66029d240e94274b2c", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}], "rationale": "AU_AML_CTF (Australian AML/CTF Act — AUSTRAC reporting framework) and FATF_R16 (FATF Recommendation 16 — travel rule for VAs). Australia is moving toward implementing FATF R16 for digital-currency exchanges; the AU framework already incorporates FATF-aligned customer-identification and reporting obligations more broadly. Aligned direction (implementation of FATF standards in Australia)."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:fe6c6d9d4e03770daeb9ad0d", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title V (CASP)"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::452::8eaf", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 63; or\n(b) a credit institution, central securities depository, investment firm, market operator, electronic money institution,\nUCITS management company, or an alternative investment fund manager that is allowed to provide crypto-asset\nservices pursuant to Article 60. EN\nL 150/114 2. Crypto-asset service providers authorised in accordance with Article 63 shall have a registered office in a Member\nState where they carry out at least part of their crypto-asset services. They shall have their place of effective management\nin the Union and at least one of the directors shall be resident in the Union.\n3. For the purposes of paragraph 1, point (a), other undertakings that are not legal persons shall only provide crypto-\nasset services if their legal form ensures a level of protection for third parties' interests equivalent to that afforded by\nlegal persons and if they are subject to equivalent prudential supervision appropriate to their legal form.\n4. Crypto-asset service providers authorised in accordance with Article 63 shall at all times meet the conditions for\ntheir authorisation.\n5."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLD 6 AML supervisory directive and EU MiCA Title V crypto-asset service provider regime are designed to coexist — obligations apply cumulatively without collision. CASPs under MiCA Title V are AMLR/AMLD6 obliged entities — aligned by design. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:512a39a487ab58882edcba7c", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}], "rationale": "AU_ATO_CRYPTO (regime A) and SG_IRAS_TAX (regime B) both relate to crypto taxation, but on close reading of the cited passages they address different specific actions. A's passage is the general Token Mapping consultation framing — broad regulatory mapping, not a tax obligation. B's passage is IRAS's GST treatment of digital payment tokens (exempting their supply from GST effective 2020). One is income-tax-regime framing, the other is consumption-tax treatment of the instrument — no obligation in A pushes against an obligation in B."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:46:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:a5b7a3df60ab91d2654eed77", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}], "rationale": "The AU_FEDREG_AML regime focuses on Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations for reporting entities, including customer identification, transaction monitoring, and suspicious activity reporting (chunk cf7cefacba3f94bc::49a::f39e). The EU_DAC8 regime focuses on tax transparency and the automatic exchange of information regarding crypto-asset users (chunk c0300673081f7232::320::7b46). While both regimes involve reporting obligations, they regulate distinct domains: one is a financial crime prevention regime, and the other is a tax information exchange regime. The obligations do not push against one another; rather, they operate in parallel to address different regulatory objectives."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:03:28Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:4922ee431a8b922cd34aaba8", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The EU_EMD2 passages discuss digital operational resilience and financial rules for the European Parliament and Council (Directive 2022/2556 and Regulation 2022/2554). The INT_BASEL_CRYPTO passages discuss Basel III capital requirements, risk-weighting exposures, and liquidity standards. The obligations in Regime A (operational resilience and financial administration) do not overlap with the obligations in Regime B (capital adequacy and risk management). Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:21:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:4922ee431a8b922cd34aaba8", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The EU_EMD2 passages discuss digital operational resilience and financial rules for the European Parliament and Council (Directive 2022/2556 and Regulation 2022/2554). The INT_BASEL_CRYPTO passages discuss capital requirements, risk-weighting exposures, and prudential standards for banks. The obligations in Regime A (operational resilience) do not conflict with the obligations in Regime B (capital adequacy); rather, they regulate distinct aspects of financial institution management. The cited passages confirm no specific obligation in Regime A pushes against a specific obligation in Regime B."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:00:42Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:c567667863edb784663a0516", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "rationale": "The EU_NIS2 passage discusses the preparation of technical standards for access controls and cryptography under Directive (EU) 2022/2555 (NIS2) and Directive (EU) 2022/2557 (Critical Entities Regulation) (chunk_id 3c9eb3a25c93f394::474::4786). The INT_BASEL_CRYPTO passage defines 'bank exposure' for capital requirements and notes that internationally active banks must adhere to Basel framework standards (chunk_id 32afd37cade34f84::3a4::1a5b). The obligations in NIS2 relate to ICT security measures (access controls, cryptography), while the obligations in Basel relate to capital adequacy and prudential supervision. These are distinct regulatory domains with no apparent overlap of obligations or conflicting requirements."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:31:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f2bbeea8688232d15850e11e", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "018117ef1e757630::428::d321", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Strengthening AML/CFT Controls of\nDigital Payment Token Service Providers\nMarch 2021 Introduction\nThis infographic sets out recent international developments and MAS' supervisory expectations on\nAML/CFT controls for the Digital Payment Token (DPT) sector.\n• This infographic is intended to raise industry awareness to the money laundering and terrorism financing (ML/TF)\nrisks in the DPT sector, and provide additional supervisory information to help DPT service providers implement\neffective policies, procedures and controls to deal with the ML/TF risks.\n• In particular, this infographic focuses on:\nI) Financial Action Task Force (FATF) Standards and recent developments;\nII) ML/TF Risks in DPT sector; and\nIII) Overview of MAS' AML/CFT requirements and expectations for the DPT sector - including key AML/CFT\nconsiderations relating to new DPT products, enhanced customer due diligence (ECDD) and value transfer.\n• The infographic supplements existing AML/CFT requirements, and should be read in conjunction with the Notice\nPS-N02 and accompanying Guidelines."}], "rationale": "The Australian regime passage (e6bb47e92e88e16c::567::36c4) discusses the token mapping and tax compliance of crypto assets in Australia. The Singaporean regime passage (018117ef1e757630::428::d321) focuses on strengthening AML/CFT controls for Digital Payment Token (DPT) service providers. While both regimes address crypto assets, the obligations described are distinct: the Australian passage outlines a tax compliance and regulatory reform agenda, whereas the Singaporean passage outlines supervisory expectations and AML/CFT controls for DPT service providers. There is no specific obligation in one regime that directly conflicts with a specific obligation in the other; rather, they regulate different aspects of the crypto ecosystem (tax vs. AML/CFT controls). Therefore, the regimes are in non_conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:09:33Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:0c6721b375934449839519c5", "label": "conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "EU_MICA_RTS (EU MiCA regulatory technical standards — detailed CASP authorisation and qualifying-holding-acquisition information requirements, including personal data of directors, qualifying holders, and beneficial owners) and SG_PDPA (Singapore PDPA — consent and disclosure restrictions for personal data). When EU CASP authorisation applications involve persons resident in SG (e.g. SG-based qualifying holders), the RTS-mandated personal-data submission engages PDPA on the SG side. Operationally resolvable via PDPA s.13(b) carve-out + competent-authority cooperation arrangements.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:15Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:21:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:0b1a5ba994a1f7852516ad0f", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::34e::4d5c", "source_doc": "d424.pdf", "page": 84, "passage": "141. Section G discusses the method by which the difference between provisions (eg specific\nprovisions, portfolio-specific general provisions such as country risk provisions or general provisions) and\nexpected losses may be included in or must be deducted from regulatory capital, as outlined in the\ndefinition of capital section of the Basel III framework (June 2011).\n\n1. Calculation of expected losses\n\n142. A bank must sum the EL amount (defined as EL multiplied by EAD) associated with its exposures\nto which the IRB approach is applied (excluding the EL amount associated with securitisation exposures)\nto obtain a total EL amount. The treatment of EL for securitisation exposures is described in paragraph 37\nof the securitisation framework.\n(i) Expected loss for exposures other than exposures subject to the supervisory slotting\ncriteria"}], "rationale": "The EU_EMD2 passages discuss the Digital Operational Resilience Act (DORA) and financial rules for the European Banking Authority, focusing on operational resilience and administrative compliance. In contrast, the INT_BASEL_GENERAL passages address banking capital adequacy, specifically the leverage ratio, expected losses, and provisions. The obligations in Regime A (operational resilience) do not impose requirements that conflict with the capital treatment rules in Regime B (Basel III leverage ratio and provisions). The regimes regulate distinct aspects of banking supervision—operational resilience versus capital adequacy—resulting in no friction between the specific obligations cited."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:09:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:cabd555fb386956332ef837a", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4a92930a8caf822::380::0a18", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 12, "passage": "Part 1 Preliminary\nSection 1-4\n(a) in relation to registration or proposed registration of a person under Part 6\nof the Act as a remittance network provider-registrable remittance\nnetwork services; or\n(b) in relation to registration or proposed registration of a person under Part 6\nof the Act as an independent remittance dealer or a remittance affiliate of a\nregistered remittance network provider-registrable remittance services; or\n(c) in relation to registration or proposed registration of a person under Part 6A\nof the Act as a virtual asset service provider-registrable virtual asset\nservices.\nrelated body corporate has the same meaning as in the Corporations Act 2001.\nsuper-agent has the meaning given by subsection 4-13(2).\ntracing information, in relation to a transfer of value, means information that\nsatisfies both of the following:\n(a) the information:\n(i) for a transfer from an"}, {"chunk_id": "c4a92930a8caf822::57d::3f76", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 28, "passage": "Part 4-Registration\nDivision 1-Management of the Remittance Sector Register and the\nVirtual Asset Service Provider Register\n4-1 Correction of entries\n(1) This section is made for the purposes of paragraphs 75(4)(a) and 76B(4)(a) of the\nAct. (2) If the AUSTRAC CEO reasonably believes that there is an error in, or omission\nfrom, an entry in the Remittance Sector Register or the Virtual Asset Service\nProvider Register, the AUSTRAC CEO may correct the error or omission. (3) As soon as reasonably practicable after making a correction of an entry under\nthis section, the AUSTRAC CEO must give notice of the correction to:\n(a) the person whose registration the entry relates to; and\n(b) if the registration is of a person as a remittance affiliate of a registered\nremittance network provider-the provider.\n4-2 Publication of register information\n(1) For the purposes of subsections 75(4) and 76B(4) of the Act, the AUSTRAC\nCEO must publish the following on AUSTRAC's website:\n(a) the details mentioned in paragraphs 75A(1)(a), (b), (c) and (f) of the Act on\nthe Remittance Sector Register;\n(b) the details mentioned in paragraphs 76C(a) and (d) of the Act on the\nVirtual Asset Service Provider Register;\n(c) information mentioned in section 4-24 of this instrument (register entry in\nrelation to suspension of registration) on the Remittance Sector Register\nand the Virtual Asset Service Provider Register."}, {"chunk_id": "c4a92930a8caf822::37f::8a4f", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 98, "passage": "mentioned in item 2 (ii) tracing information\ndo not apply\n4 the transfer of value is a merchant payment card number of the card the payer used in\nrelation to the merchant payment\n5 the transfer of value is a refund of a card number of the card the payer used in\nmerchant payment relation to the merchant payment that is\nrefunded\n6 the instruction for the transfer of value is card number of the card the payer used in\ngiven by the use of an ATM relation to the withdrawal\n7 (a) the value being transferred is money; and tracing information\n(b) the money is in a foreign country and, as\na result of the provision of an\ninternational value transfer service, the\nmoney will be in Australia; and\n(c) the beneficiary institution receives the\ntransfer message for the transfer of value\nthrough BECS\n8 the value is transferred from a self-hosted (a) payer information; and\nvirtual asset wallet (b) the"}, {"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}, {"chunk_id": "f173909614befd49::4bf::1d9e", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "Specific disclosure requirements should be augmented by a general disclosure\nrequirement.\n111 See Principles for Periodic Disclosure by Listed Entities, Final Report, Report of the Technical Committee\nof IOSCO, February 2010, pp. 16-17, available at\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD317.pdf; see also Protection of Minority\nShareholders in Listed Issuers, Final Report, Report of the Technical Committee of IOSCO in consultation\nwith the OECD, June 2009, pp.10-14, available at\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD295.pdf; see also International Disclosure Standards\nfor Cross-Border Offerings and Initial Listings by Foreign Issuers, supra, Item VII at pp. 18-19;\nDisclosure Principles for Public Offerings and Listings of Asset-backed Securities, supra, Principle III at\npp. 10-12; and International Disclosure Principles for Cross-Border Offerings and Listing of Debt\nSecurities by Foreign Issuers, Final Report, Report of the Technical Committee of IOSCO, March 2007,\nItem XI at pp. 23-24, available at https://www.iosco.org/library/pubdocs/pdf/IOSCOPD242.pdf.\n112 If there are classes of shares or other structural features that would affect share price, these should be\ndisclosed."}, {"chunk_id": "f173909614befd49::310::2c14", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "https://www.iosco.org/library/pubdocs/pdf/IOSCOPD120.pdf\n19 Adapting IOSCO International Disclosure Standards for 16\nShelf Registration Systems, Report of the Technical\nCommittee of IOSCO, March 2001,\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD118.pdf\n20 Resolution on IASC Standards, Resolution of the Presidents' 16\nCommittee of IOSCO, May 2000, http://www.iosco.org/library/resolutions/pdf/IOSCORES19.pdf\n21 Resolution on IOSCO Endorsement of Disclosure Standards 16\nto Facilitate Cross-Border Offerings and Listings by\nMultinational Issuers, Resolution of the Presidents'\nCommittee of IOSCO, September 1998,\nhttps://www.iosco.org/library/resolutions/pdf/IOSCORES17.pdf\n22 Securities Activity on the Internet, Report of the Technical 16 11\nCommittee of IOSCO, September 1998,"}, {"chunk_id": "f173909614befd49::364::fd42", "source_doc": "IOSCOPD562.pdf", "page": 186, "passage": "https://www.iosco.org/library/pubdocs/pdf/IOSCOPD184.pdf\n13 Final Report on Elements of International Regulatory 29 24\nStandards on Fees and Expenses of Investment Funds, Report of the Technical Committee of IOSCO, November 2004,\nhttp://www.iosco.org/library/pubdocs/pdf/IOSCOPD178.pdf\n14 Principles on Client Identification and Beneficial Ownership for 31 10\nthe Securities Industry, Report of IOSCO, May 2004,\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD167.pdf\n15 Report on Securities Activity on the Internet III, Report of the 31 11\nTechnical Committee of IOSCO, October 2003, https://www.iosco.org/library/pubdocs/pdf/IOSCOPD159.pdf 16 IOSCO Statement of Principles for Addressing Sell-Side Analyst 31 23\nConflicts of Interest, Report of the Technical Committee of\nIOSCO, September 2003, available at\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD150.pdf"}, {"chunk_id": "f173909614befd49::3bc::ad36", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "https://www.iosco.org/library/pubdocs/pdf/IOSCOPD83.pdf 23 International Disclosure Standards for Cross-Border 16\nOfferings and Initial Listings by Foreign Issuer, Report of IOSCO, September 1998,\nhttp://www.iosco.org/library/pubdocs/pdf/IOSCOPD81.pdf PRINCIPLES RELATING TO ISSUERS\nDocument Principles Other\nPrinciples\n24 International Equity Offers - Changes in Regulation Since 16\nApril 1996, Report of the Technical Committee of IOSCO,\nSeptember 1997,\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD71.pdf\n25 Reporting of Material Events in Emerging Markets, Report of 16\nthe Emerging Markets Committee of IOSCO, September\n1996,\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD62.pdf\n26 International Equity Offers - Changes in Regulation Since 16\nApril 1994, Report of IOSCO, September 1996,\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD61.pdf\n27 Report on Disclosure and Accounting, Report of the 16\nTechnical Committee of IOSCO, October 1994,"}], "rationale": "The AU_TRAVEL_RULE passages discuss Australia's regulatory framework for remittance networks, virtual asset service providers, and the specific implementation of FATF's 'Travel Rule' for digital currency exchanges (cf7cefacba3f94bc::383::7d9d; 30a32a386d15ba2b::4f3::edc3). In contrast, the INT_IOSCO_GENERAL passages focus on general securities regulation principles, disclosure standards, and cross-border offerings (f173909614befd49::455::1a1a; f173909614befd49::4bf::1d9e). The two regimes regulate distinct domains—financial services compliance and securities market regulation—and there is no evidence of a specific obligation in one regime conflicting with a specific obligation in the other. Therefore, the relationship is non-conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-18T11:48:14Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:bcd2ecea278af81258636ac8", "label": "conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "550958b067dc6726::41f::546c", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 24, "passage": "3.1 Standard AFSL Obligations\nAustralian financial services licence\n(a) A platform provider must hold an AFSL authorising them to issue and deal in digital asset facilities.\n(b) A platform provider is exempt from holding an AFSL for digital asset facilities if:\n(i) the total value of platform entitlements held by any one client of the platform provider does\nnot exceed $1,500 at any one time; and\n(ii) the total amount of assets held by the platform provider does not exceed $5 million at any\ntime.\nInfo Box 3 Low value exemption\nThe risks with digital asset facilities are correlated to the size and scale of the asset holding role of\nthe platform provider. Accordingly, a 'low-value facility' exemption would be introduced, similar to\nthe 'low value facility' exemption for non-cash payment facilities. It would apply to digital asset\nfacilities holding less than $1,500 per customer and less than $5 million in total.40 This exemption\nis intended to allow for innovation and experimentation in the early stages of developing a novel\nservice offering."}, {"chunk_id": "550958b067dc6726::709::b159", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 15, "passage": "2.3 Overview of proposed framework\nLicensing\nThe proposed framework would recognise certain asset holding arrangements as a financial product (a\ndigital asset facility). The existing AFSL framework would apply to any person 'carrying on a financial\nservices business in Australia' in relation to a digital asset facility. Examples of 'financial services'\ninclude:\n• dealing in a financial product (including applying for or acquiring, issuing, varying or disposing of a\nfinancial product)\n• making a market for a financial product\n• providing a custodial or depository service, and\n• providing financial product advice.\nThe issuer of a digital asset facility would be the person or persons responsible for the obligations\nowed to customers under the terms of the asset holding arrangement (platform provider). Platform\nproviders and other intermediaries performing financial services in relation to digital asset facilities\n(e.g. brokers, arrangers, agents, market makers, and advisers) would be required to hold an AFSL.\nWhile the application of the AFSL regime would be jurisdictionally limited to Australia in the usual way,\nan intermediary business in Australia, like a broker, would need to be licensed to provide services that\ninvolve dealing in digital asset facilities generally (including those not licensed or located in Australia).\nSee Part 3 for further detail about licensing obligations.\nFacility contracts\nThe proposed framework would permit digital asset facilities to be paired with other functions,\ncreating digital asset platforms. All arrangements involving digital asset facilities would be required to\nbe structured as non-discretionary arrangements.29 The term 'non-discretionary' means the\narrangements must operate according to pre-agreed and transparent rules and procedures."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}, {"chunk_id": "018117ef1e757630::4b5::9ef5", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Guidelines\n• MAS' surveillance efforts are • Existing VASPs operating in\nfocused on: (a) detecting and Singapore were required to notify\nLicensing\ndeterring unlicensed DPT activities MAS and submit licence\nSurveillance and\nin Singapore; and (b) leveraging applications by 28 Jul 2020.\ndata and blockchain analytics to Supervision\nidentify higher risk entities. • Applicants expected to\ndemonstrate understanding and\nability to mitigate ML/TF risks. Slide 5 (III) AML/CFT requirements for DPT sector\nAML/CFT requirements for digital payment token (DPT) service in Singapore\n• AML/CFT requirements are set out in MAS Notice PSN02 (issued 5 Dec 2019) and Guidelines to PSN02 (issued on 16 Mar 2020). Amendments to the Payment Services Act were passed in Parliament in Jan 2021 to expand the scope of DPT services and\nfurther updates to Notice PSN02 and Guidelines are in train to apply AML/CFT requirements to the newly scoped-in DPT services.\n• Entities that (a) deal in DPT; (b) facilitate the exchange of DPT; (c) facilitate the transmission of DPT; (d) and/or provide custodian\nwallet services, will therefore be required to be licensed as DPT service providers, and comply with the AML/CFT requirements."}], "rationale": "AU_ASIC_AFSL (Australian Financial Services Licence — entity-licensing framework for providing financial services in Australia, extended to crypto-as-financial-product per ASIC INFO 225) and SG_PSA_DPT (Singapore PSA DPT-service licence — MAS PSN02 framework). An entity providing crypto-asset services to clients in both AU and SG faces parallel licensing requirements — AU AFSL on the AU side and SG PSA DPT licence on the SG side. Operationally resolvable through dual authorisation; both regimes apply but neither prohibits compliance with the other. Severity medium because the licensing cost is real and recurring.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:28:04Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:3197bc1aaf66791ffc05ce3d", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "ba862e1f095bceac::1a6::1f0e", "source_doc": "FATF Recommendations 2012.pdf.coredownload.inline.pdf", "page": 79, "passage": "4. A country need not impose a separate licensing or registration system with respect to natural\nor legal persons already licensed or registered as financial institutions (as defined by the FATF\nRecommendations) within that country, which, under such license or registration, are\npermitted to perform VASP activities and which are already subject to the full range of\napplicable obligations under the FATF Recommendations."}], "rationale": "INT_BASEL_CRYPTO (Basel d424 — prudential treatment of crypto-asset exposures by banks) and INT_FATF_VASP (FATF VASP guidance — AML/CFT for VAs and VASPs). Both are international standards-setters addressing crypto regulation from different angles (prudential vs AML); they coordinate to provide complementary global frameworks. Aligned by design."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:10:50Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:048357e5524657b3455fb69f", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The EU MICA Title IV EMT passages regulate the disclosure and liability obligations of issuers of e-money tokens, specifically regarding the content of crypto-asset white papers and notification to competent authorities (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e). In contrast, the INT Basel Crypto passages define capital requirements, risk-weighting methodologies, and supervisory standards for banks' exposures to financial institutions (chunk_ids 32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). The obligations in MICA relate to consumer protection and market transparency for token issuers, while the obligations in Basel relate to prudential capital adequacy for banks. These are distinct regulatory domains with no apparent overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:30:09Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:d7e59a67944aa1f348568f54", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::514::0ca0", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 57, "passage": "Article 24\nGeneral principles and information to clients\n1. Member States shall require that, when providing investment services or, where appropriate, ancillary services to\nclients, an investment firm act honestly, fairly and professionally in accordance with the best interests of its clients and\ncomply, in particular, with the principles set out in this Article and in Article 25.\n2. Investment firms which manufacture financial instruments for sale to clients shall ensure that those financial\ninstruments are designed to meet the needs of an identified target market of end clients within the relevant category\nof clients, the strategy for distribution of the financial instruments is compatible with the identified target market, and the\ninvestment firm takes reasonable steps to ensure that the financial instrument is distributed to the identified target\nmarket. An investment firm shall understand the financial instruments they offer or recommend, assess the compatibility of the\nfinancial instruments with the needs of the clients to whom it provides investment services, also taking account of the\nidentified target market of end clients as referred to in Article 16(3), and ensure that financial instruments are offered or\nrecommended only when this is in the interest of the client.\n3."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "rationale": "The AU_TTR_THRESHOLD regime regulates the reporting of physical cash transactions exceeding A$10,000 to AUSTRAC (chunk_ids 6dfe4e63b9fb3c74::3bc::1a3f, 254ca2d92d196180::377::d0c6). The EU_MIFID2 regime regulates investment firms' conduct of business, specifically the provision of investment services and the suitability of financial instruments (chunk_ids 28dfda0f6a6539b6::514::0ca0, 28dfda0f6a6539b6::502::1957). The obligations in MIFID2 relate to client suitability, information disclosure, and professional conduct, whereas the obligations in AU_TTR relate to cash transaction reporting thresholds. These are distinct regulatory domains with no overlapping obligations that would create a conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:18:26Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:eb3b0211ac2383a618017286", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "0fc4f857c226f510::375::66b5", "source_doc": "Corporations_Act_2001_Vol1.pdf", "page": 296, "passage": "Part 1.6 Interaction with Australian Charities and Not-for-profits Commission Act Section 111L\nProvisions of this Act that do not apply to bodies corporate registered under the\nACNC Act\nItem Column 1 Column 2\nProvision(s) Topic\n2 section 138 ASIC may direct company to lodge\nconsolidated constitution\n3 section 139 Company must send copy of\nconstitution to member\n4 subsection 142(2), section 146 and Company must notify ASIC of\nsubsection 146A(2) changes of address\n5 (a) sections 180 to 183; and Duties of directors etc. (b) section 185, to the extent that it\nrelates to sections 180 to 183\n6 section 188, to the extent it relates to Responsibility of secretaries and\na provision mentioned in another directors for certain contraventions\nitem of this table\n7 sections 191 to 194 Interests of directors\n8 (a) sections 201L and 205A to 205C; Public information about directors\nand etc."}], "evidence_b": [{"chunk_id": "3d9b3d4849297e91::3c6::7b85", "source_doc": "2025_CP_Prudential_Treatment_Cryptoassets.pdf", "page": null, "passage": "Preface | 4\n1.6 MAS invites comments from banks and other interested parties. Please refer to Annex A for the list of\nquestions.\n1.7 Please note that all submissions received will be published and attributed to the respective respondent\nunless they expressly request MAS not to do so. As such, if respondents would like\n(a) their whole submission or part of it (but not their identity), or\n(b) their identity along with their whole submission,\nto be kept confidential, please expressly state so in the submission to MAS. MAS will only publish\nnon-anonymous submissions. In addition, MAS reserves the right not to publish any submission\nreceived where MAS considers it not in the public interest to do so, such as where the submission\nappears to be libelous or offensive.\n1.8 Please submit written comments via email to prudential_policy_dept@mas.gov.sg using the suggested\ntemplate by 28 April 2025. Prudential Treatment & Disclosures of Cryptoasset Exposures | 5\n2."}], "rationale": "The evidence from the Australian Corporations Act (Regime A) focuses on the interaction with the Australian Charities and Not-for-profits Commission Act, detailing specific provisions regarding company constitutions, director duties, and winding up (chunk 0fc4f857c226f510::375::66b5). The evidence from the Monetary Authority of Singapore's Prudential Treatment & Disclosures of Cryptoasset Exposures (Regime B) is a consultation paper inviting comments on prudential standards for cryptoasset exposures and detailing submission procedures (chunk 3d9b3d4849297e91::3c6::7b85). The obligations and topics regulated by the two regimes are distinct; one governs corporate governance and winding up, while the other governs prudential standards for digital assets. There is no specific obligation in the Australian Corporations Act that pushes against a specific obligation in the Singapore MAS Prudential Crypto regime. Therefore, the regimes are in different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:997830a28c118ee62e71c293", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "FATF_R16 (FATF Recommendation 16 / VA guidance — international AML travel-rule standard) and SG_MAS_AML_GENERAL (MAS's AML/CFT supervisory framework for DPT providers in Singapore). MAS's framework explicitly implements FATF standards including R16 for DPT providers; the regimes reinforce each other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:43127066a6344385338d8756", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "evidence_b": [{"chunk_id": "6d8a84a9f3d6e9e4::480::ac46", "source_doc": "Guidelines_to_MAS_Notice_SFA04-N02_2025.pdf", "page": 5, "passage": "2 The FSM Sanctions Regulations include the regulations issued under section 192 read with sections 15(1)(b) and 219(d)\nof the FSM Act. Please refer to the following link for the FSM Sanctions Regulations:\nhttps://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions/regulations-for-targeted-financial-\nsanctions. Currently, the relevant FSM Sanctions Regulations are those relating to the Democratic People's Republic of\nKorea and Iran. concerns. Other support functions such as operations, human resource or\ntechnology also play a role to help mitigate the ML/TF risks that the CMI faces. The AML/CFT compliance function is typically the contact point regarding all\nAML/CFT issues for domestic and foreign authorities, including supervisory\nauthorities, law enforcement authorities and financial intelligence units.\n1-4-14 As the third line of defence, the CMI's internal audit function or an equivalent\nfunction plays an important role in independently evaluating the AML/CFT risk\nmanagement framework and controls for purposes of reporting to the audit\ncommittee of the CMI's board of directors, or a similar oversight body."}, {"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "EU_GDPR (cross-border data transfer principles) and SG_MAS_AML_GENERAL (MAS AML/CFT supervisory framework for DPT providers, including data-collection and sanctions-screening obligations). When EU customer data flows to SG-licensed entities for AML compliance, GDPR Chapter V restrictions engage. Operationally resolvable via GDPR Art. 6(1)(c) + Chapter V mechanisms (SCCs, adequacy, or derogation). Same conflict shape as EU TFR ↔ EU GDPR in the careful cohort.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:49Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:12:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:34b9c2154ca244d47357531b", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "evidence_b": [{"chunk_id": "14cb9eb911d15322::42b::fe23", "source_doc": "2023_Response_PS_Regulations_Amendments.pdf", "page": 22, "passage": "LTD Question 1. MAS seeks comments on the proposed amendments to the Payment Services\nRegulations.\n1. The term safeguarding institution needs to be defined for the purposes of\nRegulation16C. Since DPTSP can self custodize it would be good to have a clear\ndefinition of safeguarding customer's assets. The term \"safeguarding\" is also not\nused/defined in Securities and Futures Act or in the Securities and Futures\n(licensing and conduct of business) regulations in the context of customer\nassets.\n2. It is not clear in these amendments whether a PSA license is a blanket license\nthat will allow the licensee to conduct all of the digital payment token services\n(i.e. broking dealing in DPT, DPT Exchange, DPT Custody) under one PSA license 2 April 2024 | 26\nor would a licensee be granted a PSA license for specific digital payment token\nservices? Trying to draw an analogy here from the Capital Market Services\nLicense (CMSL) where each CMSL holder is given a license outlining the activities\nthat they can do under the CMSL license.\n8 Interactive Brokers Question 1."}, {"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}], "rationale": "The EU_EMD2 passages discuss the Digital Operational Resilience Act (DORA) and financial rules for the European Authority (Article 81), which are unrelated to the Payment Services Act (PS Act) or digital payment token services. Conversely, the SG_PSA_GENERAL passages discuss the Payment Services Act, Digital Payment Token Services (DPT), and transitional exemptions, which are unrelated to EU operational resilience. The regimes regulate distinct domains (EU financial operational resilience vs. Singapore payment services regulation), resulting in no overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:04:42Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:351c2002ff519f7c23369225", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLD6"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The EU AMLD6 passage (chunk 85307f9e2a040982::14a::134d) discusses the 'digital operational resilience for the financial sector' and references Directive (EU) 2022/2556. The INT IOSCO GENERAL passage (chunk f173909614befd49::455::1a1a) outlines the 'Objectives and Principles of Securities Regulation' and the 'IOSCO Principles' as key standards for sound financial systems. The regimes regulate distinct domains: EU AMLD6 focuses on operational resilience and financial sector security, while IOSCO focuses on securities regulation and disclosure standards. There is no specific obligation in one regime that pushes against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:41:53Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:f3d7d5a27ca4c2807727619d", "label": "non_conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::25d::6825", "source_doc": "d424.pdf", "page": 85, "passage": "150. At national supervisory discretion, banks using both the standardised and IRB approaches may\nrely on their internal methods for allocating general provisions for recognition in capital under either the\nstandardised or IRB approach, subject to the following conditions. Where the internal allocation method\nBasel III: Finalising post-crisis reforms 81\n\nis made available, the national supervisor will establish the standards surrounding their use. Banks will\nneed to obtain prior approval from their supervisors to use an internal allocation method for this purpose.\n\n3. Treatment of EL and provisions"}], "rationale": "The EU GDPR passages regulate the processing of personal data, including legal bases, purpose limitation, and transfers to third countries (e.g., Article 6, Article 44, Recital 89). The INT_BASEL_GENERAL passages regulate banking capital adequacy, specifically the leverage ratio, general provisions, and expected losses (e.g., paragraph 11, paragraph 150). The obligations in the GDPR relate to data privacy and protection, while the obligations in the Basel framework relate to financial risk management and capital requirements. There is no specific obligation in the GDPR that pushes against a specific obligation in the Basel framework; they govern distinct domains of regulation."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:22:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:56943f6914e1c3a403ff2349", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::3c5::d461", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 33, "passage": "80. Despite the many and frequently changing marketing terms and innovative\nbusiness models developed in this sector, the FATF envisions very few VA\narrangements without VASPs involved at some stage if countries apply the\ndefinition correctly. Countries should take particular care to assess any claims that\nbusinesses may make as to models of decentralization or distributed services, and\nconduct their own assessment of the business model in line with its risk and their\nability to mitigate these risks.\n\n81. As previously stated, the FATF Standards are technology neutral. As such, the FATF\ndoes not seek to regulate the technology that underlies VAs or VASP activities.\nRather the FATF seeks to regulate natural or legal persons behind such technologies\n\n32  UPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS\nthat conduct as a business the aforementioned VASP activities on behalf of another\nnatural or legal person."}], "rationale": "The regimes regulate distinct domains. Regime A (AU_APRA_CPS230) focuses on operational risk management, business continuity, and the resilience of APRA-regulated entities to disruptions, including the management of service providers. Regime B (INT_FATF_VASP) focuses on Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) obligations regarding Virtual Asset Service Providers (VASPs). The evidence for Regime A discusses maintaining critical operations and meeting prudential obligations (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c), while the evidence for Regime B discusses the definition of VASPs and the FATF's technology-neutral approach to regulating the natural or legal persons behind them (chunk_ids 85240528438654b9::1cd::07d7, 85240528438654b9::3c5::d461). There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other; rather, they address different aspects of financial regulation (resilience vs. AML/CFT)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:38:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b90829e96f7b9d31ab88e35c", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}], "rationale": "The AU_TRAVEL_RULE passages explicitly state that Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges and is currently consulting on extending it (chunk_ids cf7cefacba3f94bc::383::7d9d, 30a32a386d15ba2b::4f3::edc3). The INT_FATF_GENERAL passages provide general international standards and guidance on AML/CFT risk assessment (chunk_id fe52dd87e13dba41::261::59a4). The evidence confirms that the Australian regime is in a transitional state regarding the specific FATF Travel Rule requirement, while the international regime provides the standard against which the implementation is being assessed. This is a matter of implementation status rather than a direct regulatory conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:08:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:06818c76e7f746321c2abbad", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}], "rationale": "The AU_ASIC_CRYPTO passages focus on the licensing and classification of crypto-assets as financial products under the Corporations Act 2001 (e.g., 'When could a digital asset be or involve a financial product', 'licensing entities that provide financial services'). The EU_GDPR passages focus on the lawful processing of personal data, including the legal basis for processing and the transfer of data to third countries (e.g., 'legal basis may contain specific provisions', 'General principle for transfers'). The obligations in the ASIC regime regarding financial product definitions and licensing do not impose specific, conflicting obligations on the processing of personal data that would trigger the GDPR's data protection requirements. Therefore, the regimes regulate distinct domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:41:19Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:64d68bfea8fce83fff1000da", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "rationale": "The AU_PRIVACY regime regulates the cross-border disclosure of personal information, requiring entities to take reasonable steps to ensure overseas recipients comply with Australian Privacy Principles (APPs) and making the entity accountable for the recipient's acts (e9f6b0a9e797777d::5d6::e5ff). The EU_EMD2 regime regulates digital operational resilience for the financial sector (85307f9e2a040982::14a::134d). The obligations in the EU_EMD2 text relate to financial rules and operational resilience, which are distinct from the data protection and cross-border information flow obligations in the AU_PRIVACY text. There is no specific obligation in EU_EMD2 that pushes against a specific obligation in AU_PRIVACY; the regimes regulate different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:00:28Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:95a9aeee466b612db1cf4eee", "label": "non_conflict", "regime_a": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "The EU regime regulates the solicitation of clients by third-country crypto-asset service providers (reverse solicitation exemption), while the MAS regime focuses on prudential capital requirements for stablecoin issuers and payment service providers. The evidence from Regime A discusses client initiative and solicitation (chunk 25cbbd878a1b21d3::4f8::561c), whereas the evidence from Regime B discusses risk-based capital frameworks and 'same activities, same risk, same regulation' principles (chunk 7c04f2a0bd85290a::449::02f2). These obligations regulate distinct aspects of the crypto-asset ecosystem and do not impose conflicting requirements on the same specific operational activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:edd36cfc51f16c047cc75eb9", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3c8::f259", "source_doc": "d424.pdf", "page": 39, "passage": "67 See Annex 10 of Basel II (June 2006) for an overview of methodologies for the capital treatment of transactions secured by\nfinancial collateral under the standardised and IRB approaches.\n\n68 Alternatively, banks with appropriate supervisory approval may instead use the Internal Model Method to determine the\nexposure amount, taking into account collateral.\nBasel III: Finalising post-crisis reforms 35\n\n(ii) On-balance sheet netting\n\n135. Where banks have legally enforceable netting arrangements for loans and deposits that meet the\nconditions in paragraph 190 they may calculate capital requirements on the basis of net credit exposures\nas set out in that paragraph.\n(iii) Guarantees and credit derivatives\n\n136. Where guarantees or credit derivatives fulfil the minimum operational conditions set out in\nparagraphs 191 to 193, banks may take account of the credit protection offered by such credit risk\nmitigation techniques in calculating capital requirements."}, {"chunk_id": "32afd37cade34f84::168::f255", "source_doc": "d424.pdf", "page": 7, "passage": "4 Standards on capital requirements for banks' equity investments in funds are available at www.bis.org/publ/bcbs266.pdf; and\nfor capital requirements for bank exposures to central counterparties are set out in Section XI of the counterparty credit risk\nstandards.\nBasel III: Finalising post-crisis reforms 3\n\nA. Individual exposures\nDue diligence requirements"}, {"chunk_id": "cbb1d8ea33595d81::485::a2a2", "source_doc": "bcbs189.pdf", "page": 5, "passage": "Several of the capital requirements introduced by the Committee to mitigate the\nrisks arising from firm-level exposures among global financial institutions will also help to\naddress systemic risk and interconnectedness. These include:\nBasel III: A global regulatory framework for more resilient banks and banking systems 7  capital incentives for banks to use central counterparties for over-the-counter\nderivatives;\n higher capital requirements for trading and derivative activities, as well as complex\nsecuritisations and off-balance sheet exposures (eg structured investment vehicles);\n higher capital requirements for inter-financial sector exposures; and\n the introduction of liquidity requirements that penalise excessive reliance on short\nterm, interbank funding to support longer dated assets. B. Introducing a global liquidity standard\n34. Strong capital requirements are a necessary condition for banking sector stability\nbut by themselves are not sufficient. A strong liquidity base reinforced through robust\nsupervisory standards is of equal importance. To date, however, there have been no\ninternationally harmonised standards in this area."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}, {"chunk_id": "f173909614befd49::4bf::1d9e", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "Specific disclosure requirements should be augmented by a general disclosure\nrequirement.\n111 See Principles for Periodic Disclosure by Listed Entities, Final Report, Report of the Technical Committee\nof IOSCO, February 2010, pp. 16-17, available at\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD317.pdf; see also Protection of Minority\nShareholders in Listed Issuers, Final Report, Report of the Technical Committee of IOSCO in consultation\nwith the OECD, June 2009, pp.10-14, available at\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD295.pdf; see also International Disclosure Standards\nfor Cross-Border Offerings and Initial Listings by Foreign Issuers, supra, Item VII at pp. 18-19;\nDisclosure Principles for Public Offerings and Listings of Asset-backed Securities, supra, Principle III at\npp. 10-12; and International Disclosure Principles for Cross-Border Offerings and Listing of Debt\nSecurities by Foreign Issuers, Final Report, Report of the Technical Committee of IOSCO, March 2007,\nItem XI at pp. 23-24, available at https://www.iosco.org/library/pubdocs/pdf/IOSCOPD242.pdf.\n112 If there are classes of shares or other structural features that would affect share price, these should be\ndisclosed."}, {"chunk_id": "f173909614befd49::310::2c14", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "https://www.iosco.org/library/pubdocs/pdf/IOSCOPD120.pdf\n19 Adapting IOSCO International Disclosure Standards for 16\nShelf Registration Systems, Report of the Technical\nCommittee of IOSCO, March 2001,\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD118.pdf\n20 Resolution on IASC Standards, Resolution of the Presidents' 16\nCommittee of IOSCO, May 2000, http://www.iosco.org/library/resolutions/pdf/IOSCORES19.pdf\n21 Resolution on IOSCO Endorsement of Disclosure Standards 16\nto Facilitate Cross-Border Offerings and Listings by\nMultinational Issuers, Resolution of the Presidents'\nCommittee of IOSCO, September 1998,\nhttps://www.iosco.org/library/resolutions/pdf/IOSCORES17.pdf\n22 Securities Activity on the Internet, Report of the Technical 16 11\nCommittee of IOSCO, September 1998,"}, {"chunk_id": "f173909614befd49::364::fd42", "source_doc": "IOSCOPD562.pdf", "page": 186, "passage": "https://www.iosco.org/library/pubdocs/pdf/IOSCOPD184.pdf\n13 Final Report on Elements of International Regulatory 29 24\nStandards on Fees and Expenses of Investment Funds, Report of the Technical Committee of IOSCO, November 2004,\nhttp://www.iosco.org/library/pubdocs/pdf/IOSCOPD178.pdf\n14 Principles on Client Identification and Beneficial Ownership for 31 10\nthe Securities Industry, Report of IOSCO, May 2004,\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD167.pdf\n15 Report on Securities Activity on the Internet III, Report of the 31 11\nTechnical Committee of IOSCO, October 2003, https://www.iosco.org/library/pubdocs/pdf/IOSCOPD159.pdf 16 IOSCO Statement of Principles for Addressing Sell-Side Analyst 31 23\nConflicts of Interest, Report of the Technical Committee of\nIOSCO, September 2003, available at\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD150.pdf"}, {"chunk_id": "f173909614befd49::3bc::ad36", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "https://www.iosco.org/library/pubdocs/pdf/IOSCOPD83.pdf 23 International Disclosure Standards for Cross-Border 16\nOfferings and Initial Listings by Foreign Issuer, Report of IOSCO, September 1998,\nhttp://www.iosco.org/library/pubdocs/pdf/IOSCOPD81.pdf PRINCIPLES RELATING TO ISSUERS\nDocument Principles Other\nPrinciples\n24 International Equity Offers - Changes in Regulation Since 16\nApril 1996, Report of the Technical Committee of IOSCO,\nSeptember 1997,\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD71.pdf\n25 Reporting of Material Events in Emerging Markets, Report of 16\nthe Emerging Markets Committee of IOSCO, September\n1996,\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD62.pdf\n26 International Equity Offers - Changes in Regulation Since 16\nApril 1994, Report of IOSCO, September 1996,\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD61.pdf\n27 Report on Disclosure and Accounting, Report of the 16\nTechnical Committee of IOSCO, October 1994,"}], "rationale": "INT_BASEL_CRYPTO and INT_IOSCO_GENERAL are both international financial-regulatory standards bodies. Basel addresses banking prudential treatment (capital requirements for crypto exposures); IOSCO addresses securities regulation principles (disclosure, cross-border offerings). They are designed to operate as complementary pillars of the global financial regulatory architecture rather than as conflicting regimes; BCBS-IOSCO frequently publish joint reports. The cited passages confirm they regulate distinct but coordinated concerns within the same international standards framework."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:28:00Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:388ff80a70d489fc0fe51d33", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "The Basel III framework passage (Regime A) discusses accounting treatment for fiduciary assets and leverage ratio exposure measures. The Singapore PSA DPT passage (Regime B) concerns the licensing and AML/CFT obligations of Digital Payment Token service providers under the Payment Services Act. The obligations in Regime A relate to banking capital and accounting standards, while the obligations in Regime B relate to payment services regulation and anti-money laundering. The regimes regulate distinct domains and do not impose conflicting obligations on the same entity or transaction type."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:01:52Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:d641232c5bc20e9a723d06f3", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "The Basel III framework (Regime A) regulates banking capital, leverage ratios, and risk-weighted assets (RWA) for banks. The Singapore Stablecoin framework (Regime B) regulates Single Currency Stablecoins (SCS) issued in Singapore under the Payment Services Act. The passages provided for Regime A discuss accounting treatment for fiduciary assets and general provisions (chunk 32afd37cade34f84::34b::8d30), while Regime B defines the scope of the stablecoin regulatory regime and distinguishes SCS from other digital payment tokens (chunk 58f45cd2ef3de201::36c::e2f6). There is no specific obligation in the Basel framework that conflicts with the issuance or regulation of stablecoins under the Singapore regime. The regimes operate in different domains (banking capital vs. digital asset issuance) and do not impose mutually exclusive requirements on the same entity or transaction type."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:51:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:3bf75aa96af5d3de96250f20", "label": "non_conflict", "regime_a": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "The IOSCO General Principles passage (chunk_id f173909614befd49::455::1a1a) outlines high-level international standards for securities regulation and cooperation, focusing on disclosure, clearing, and settlement. The SG Stablecoin passage (chunk_id 58f45cd2ef3de201::36c::e2f6) describes a specific domestic regulatory framework for Single-Currency Stablecoins (SCS) under the Payment Services Act 2019. The two regimes regulate different domains: IOSCO provides general international principles for securities markets, while the SG Stablecoin regime addresses the specific licensing and operational requirements for digital payment tokens and stablecoins in Singapore. There is no specific obligation in IOSCO that conflicts with the specific obligations of the SG Stablecoin regime."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:13:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:d1ed6b9d8084b7b98d271cf3", "label": "non_conflict", "regime_a": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}, {"chunk_id": "25cbbd878a1b21d3::298::6f7d", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 43, "passage": "28. Third-country firms should be able to provide records tracking the relationship with the\nclient and, in particular, whether the client has taken the initiative to receive crypto asset\nservices with respect to a new product.\n\n5.4 When is a crypto-asset or a crypto-asset service of the same\ntype as another one (Guideline 4)\n\n29. The reverse solicitation regime leaves open the possibility for a third-country firm to\nmarket crypto-assets or crypto-asset services or activities of the same type in the context\nof the relationship started at the own exclusive initiative of a given client, subject to the\nthird-country firm also complying with Guideline 3 above."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The EU_REVERSE_SOLICITATION regime regulates the authorization and solicitation of crypto-asset services for third-country firms targeting EU clients (chunk_ids 25cbbd878a1b21d3::4f8::561c, 25cbbd878a1b21d3::298::6f7d). The INT_BASEL_CRYPTO regime regulates capital requirements, risk-weighting, and exposure definitions for banks (chunk_ids 32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). The obligations in Regime A relate to marketing and client acquisition, while the obligations in Regime B relate to prudential capital and risk management. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B. Therefore, the regimes are in different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:19:43Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:0af6676d076eb9270d73b8aa", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "0fc4f857c226f510::375::66b5", "source_doc": "Corporations_Act_2001_Vol1.pdf", "page": 296, "passage": "Part 1.6 Interaction with Australian Charities and Not-for-profits Commission Act Section 111L\nProvisions of this Act that do not apply to bodies corporate registered under the\nACNC Act\nItem Column 1 Column 2\nProvision(s) Topic\n2 section 138 ASIC may direct company to lodge\nconsolidated constitution\n3 section 139 Company must send copy of\nconstitution to member\n4 subsection 142(2), section 146 and Company must notify ASIC of\nsubsection 146A(2) changes of address\n5 (a) sections 180 to 183; and Duties of directors etc. (b) section 185, to the extent that it\nrelates to sections 180 to 183\n6 section 188, to the extent it relates to Responsibility of secretaries and\na provision mentioned in another directors for certain contraventions\nitem of this table\n7 sections 191 to 194 Interests of directors\n8 (a) sections 201L and 205A to 205C; Public information about directors\nand etc."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "The evidence from the Australian Corporations Act (Regime A) focuses on corporate governance, director duties, and the interaction with the Australian Charities and Not-for-profits Commission Act (chunk 0fc4f857c226f510::375::66b5). The evidence from the Singapore PDPA (Regime B) focuses on the collection, use, and disclosure of personal data, specifically the requirement for consent (chunk 0e996ae99839f19e::37b::85a8). The obligations in Regime A relate to the internal management and registration of bodies corporate, while the obligations in Regime B relate to the privacy and handling of personal data. These are distinct regulatory domains with no apparent overlap or direct conflict between the specific obligations cited."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:b4f13abb3e39b0e8567b5f74", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiFID II"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::49c::69f4", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 53, "passage": "Member States shall require that investment firms and market operators operating an MTF or an OTF establish,\npublish and maintain and implement transparent and non-discriminatory rules, based on objective criteria, governing\naccess to its facility.\n4. Member States shall require that investment firms and market operators operating an MTF or an OTF have\narrangements to identify clearly and manage the potential adverse consequences for the operation of the MTF or OTF,\nor for the members or participants and users, of any conflict of interest between the interest of the MTF, the OTF, their\nowners or the investment firm or market operator operating the MTF or OTF and the sound functioning of the MTF or\nOTF.\n5. Member States shall require that investment firms and market operators operating an MTF or OTF comply with\nArticles 48 and 49 and have in place all the necessary effective systems, procedures and arrangements to do so.\n6. Member States shall require that investment firms and market operators operating an MTF or an OTF clearly inform\nits members or participants of their respective responsibilities for the settlement of the transactions executed in that\nfacility."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU DORA ICT operational-resilience regulation and EU MiFID II investment-firm conduct directive are designed to coexist — obligations apply cumulatively without collision. MiFID II investment firms are EU financial entities under DORA — ICT-resilience regime applies cumulatively. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:26:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:a7bb57e801592e9a0ad4e78c", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}, {"chunk_id": "28dfda0f6a6539b6::4f2::95d6", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Such a warning may be\nprovided in a standardised format;\n(d) the investment firm complies with its obligations under Article 23.\n5. The investment firm shall establish a record that includes the document or documents agreed between the\ninvestment firm and the client that set out the rights and obligations of the parties, and the other terms on which\nthe investment firm will provide services to the client. The rights and duties of the parties to the contract may be\nincorporated by reference to other documents or legal texts.\n6. The investment firm shall provide the client with adequate reports on the service provided in a durable medium. Those reports shall include periodic communications to clients, taking into account the type and the complexity of\nfinancial instruments involved and the nature of the service provided to the client and shall include, where applicable, the\ncosts associated with the transactions and services undertaken on behalf of the client. When providing investment advice, the investment firm shall, before the transaction is made, provide the client with a\nstatement on suitability in a durable medium specifying the advice given and how that advice meets the preferences,\nobjectives and other characteristics of the retail client."}, {"chunk_id": "28dfda0f6a6539b6::514::0ca0", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 57, "passage": "Article 24\nGeneral principles and information to clients\n1. Member States shall require that, when providing investment services or, where appropriate, ancillary services to\nclients, an investment firm act honestly, fairly and professionally in accordance with the best interests of its clients and\ncomply, in particular, with the principles set out in this Article and in Article 25.\n2. Investment firms which manufacture financial instruments for sale to clients shall ensure that those financial\ninstruments are designed to meet the needs of an identified target market of end clients within the relevant category\nof clients, the strategy for distribution of the financial instruments is compatible with the identified target market, and the\ninvestment firm takes reasonable steps to ensure that the financial instrument is distributed to the identified target\nmarket. An investment firm shall understand the financial instruments they offer or recommend, assess the compatibility of the\nfinancial instruments with the needs of the clients to whom it provides investment services, also taking account of the\nidentified target market of end clients as referred to in Article 16(3), and ensure that financial instruments are offered or\nrecommended only when this is in the interest of the client.\n3."}, {"chunk_id": "28dfda0f6a6539b6::52e::014d", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 57, "passage": "All information, including marketing communications, addressed by the investment firm to clients or potential\nclients shall be fair, clear and not misleading. Marketing communications shall be clearly identifiable as such.\n4. Appropriate information shall be provided in good time to clients or potential clients with regard to the investment\nfirm and its services, the financial instruments and proposed investment strategies, execution venues and all costs and\nrelated charges. That information shall include the following:\n(a) when investment advice is provided, the investment firm must, in good time before it provides investment advice,\ninform the client:\n(i) whether or not the advice is provided on an independent basis;\n(ii) whether the advice is based on a broad or on a more restricted analysis of different types of financial instruments\nand, in particular, whether the range is limited to financial instruments issued or provided by entities having close\nlinks with the investment firm or any other legal or economic relationships, such as contractual relationships, so\nclose as to pose a risk of impairing the independent basis of the advice provided;\n(iii) whether the investment firm will provide the client with a periodic assessment of the suitability of the financial\ninstruments recommended to that client;"}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::45b::7c2f", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "However, to ensure market integrity and public trust, it is critical that all\nsingle-labelled SCS meet the same regulatory requirements. As a result, we support the\nMAS's proposal for single-labelled SCS, but only under the condition that non-banks would\nbe also subject the same regulatory requirements for their SCS issuance services. Moreover, we would recommend that MAS adopts the term \"regulated stablecoins\" as we\nfind that it reflects MAS's aspiration to develop a digital assets ecosystem by introducing a\nrobust regulatory framework for SCS. In parallel, we believe that it would be beneficial if\nSCS issuers would be able to add on the single label of SCS, e.g. \"regulated stablecoin -\nCompany A\". This could help customers differentiate their SCS offerings, encourage\ncompetition and consequently attract more issuers and contribute to the development of\nthe digital asset ecosystem. Question 5. MAS seeks comments on whether the proposed reserve asset requirements are\nappropriate, and whether there may be unintended consequences that may affect the\ndevelopment of Singapore's digital asset ecosystem."}, {"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}, {"chunk_id": "7c04f2a0bd85290a::40f::805d", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 37, "passage": "We believe that a single label for bank and non-bank issued SCS is sufficient as the\npurpose of the label is to highlight to customers that a given issuer is adequately\nregulated and a single label serves that purpose. We believe the term 'regulated 15 August 2023 | 50\nstablecoin' is likely the clearest option for the purpose of achieving the aforementioned\npurpose. Perhaps 'locally regulated stablecoin' might also be applied to distinguish a\nstablecoin regulated by MAS from stablecoins which are regulated elsewhere using\ndifferent standards. Question 5. MAS seeks comments on whether the proposed reserve asset requirements are\nappropriate, and whether there may be unintended consequences that may affect the\ndevelopment of Singapore's digital asset ecosystem. We believe that the proposed reserve asset requirements are appropriate, however\nlimiting the pegs to the Singaporean dollar and Group of Ten Currencies, seems short\nsighted as it precludes SCS projects backed by other important currencies like CNH from\nbeing regulated."}, {"chunk_id": "33d059aa86716ddd::4ed::8511", "source_doc": "2022_CP_Stablecoin_Regulatory_Approach.pdf", "page": 6, "passage": "3.5 A wide range of stablecoins currently exist, varying in terms of their asset-\npegging, as well as the mechanism that upholds the stability of the stablecoins' value\nagainst the pegged asset(s). MAS intends to focus its regulatory regime on:\nSingle-currency pegged stablecoins (SCS) - As compared to other types of\nstablecoins (such as those pegged to a basket of currencies or other\nassets such as commodities), SCS has a stronger use case for payment and\nsettlement.\nNon-SCS will continue to be subject to the existing DPT regime under the\nPS Act. MAS views such stablecoins as being less stable in nominal value\nand should be treated differently from SCS.\nIn addition, even among SCS, there is variation in the stabilisation\nmechanism. MAS views stablecoins which are algorithmically-pegged,\nunbacked or backed by other cryptocurrencies to be more susceptible to\nvolatility in value. Correspondingly, such stablecoins will also continue to\nbe treated as DPTs.\nSCS issued in Singapore - The immediate priority of MAS is to elevate the\nstandard of SCS issued in Singapore. Our regulatory perimeter is thus\nscoped based on MAS' ability to directly impose requirements on the\nreserve management, redemption policies and prudential standards of\nthe SCS issuer."}, {"chunk_id": "7c04f2a0bd85290a::451::2fcf", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 37, "passage": "We further note that SCS issued by banks will similarly be recognised as\nMAS-regulated SCS. We therefore agree that such treatment will serve the regulatory\nobjective of maintaining a high degree of value stability of SCS. Question 4. MAS seeks comments on whether it is appropriate to have a single label for bank and\nnon-bank issued SCS that MAS regulates. MAS also seeks views on the three options to\nlabel the SCS, and whether there are alternative terms that may be used to distinguish\nstablecoins that are regulated by MAS, from other types of stablecoins. 15 August 2023 | 54\nHM agrees that it is appropriate to have a single label for bank and non-bank issued SCS\nregulated by MAS. We believe that it would cause unnecessary confusion to the public if\nseparate labels were adopted. We are of the view that \"MAS-Regulated Single Currency Stablecoin\" is the preferable\nterm that should be given. Specifically, we strongly believe that incorporating the term\n\"Single Currency Stablecoin\" will distinguish regulated SCS from other types of stablecoin,\nwhich are given a different regulatory treatment."}], "rationale": "The EU_MIFID2 passages regulate the conduct of investment firms, specifically obligations regarding product governance, suitability assessments, and client communication (e.g., Article 1, Article 24, Article 25). The SG_STABLECOIN passages regulate the issuance and classification of specific digital assets (Single Currency Stablecoins) under the Payment Services Act. The obligations in MIFID2 apply to firms providing investment services, whereas the SG_STABLECOIN framework applies to the token assets themselves and their issuers. There is no specific obligation in MIFID2 that conflicts with the specific obligations in the SG_STABLECOIN regime; rather, they govern distinct domains of financial activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.78, "record_type": "non_conflict", "pair_id": "non_conflict:995b712f12e57a02f1fe2865", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}, {"chunk_id": "abc2247bc6415d1d::5c7::68f5", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 10, "passage": "You should obtain the sum of the absolute values of\nexempt supplies from each category to report in your GST return. Category of exempt supplies Exchange gain (loss) for digital\nfor the accounting period from payment tokens\nJan 2020 to Mar 2020\nExchange gain (loss) for digital (200)\npayment tokens Exchange gain (loss) for foreign 400\ncurrency\nInterest received from deposit with 300\nbanks\nValue of exempt supplies |(200)| + 400 + 300\n= $900\nQ9 Can I report the value of supply of digital payment tokens issued during\nmy ICO based on the proceeds received, and then report the value of\nsupply for subsequent transactions based on realised gain or loss? A9 Yes, you may report the proceeds received as the value of supply for ICO\ntransactions. For subsequent exchanges of the tokens for fiat currency or\nother digital payment tokens, you may choose to report the realised gain or\nloss. This is allowed as long as you apply the method chosen consistently.\n14 Contact information\n10.1 For enquiries on this e-Tax Guide, please contact the Goods and Services\nTax Division at www.iras.gov.sg (select \"Contact Us\")\n15 Updates and Amendments\nDate of\nAmendments made\namendment\n1 3 Aug 2022 • Editorial changes.\n• Amended paragraphs 3.6 and 3.8 to reflect the\ndefinition in Income Tax e-Tax Guide on digital\npayment tokens.\n• Added paragraph 5.11 to clarify that if a digital\npayment token is listed on an exchange, IRAS will\nregard the token as suitable for use as a medium\nof exchange."}], "rationale": "EU_DAC8 (EU directive on administrative cooperation for crypto-asset reporting, implementing the OECD's Crypto-Asset Reporting Framework — CARF) and SG_IRAS_TAX (IRAS GST treatment of digital payment tokens). Both implement tax-policy treatments of crypto consistent with international (OECD-led) approaches; DAC8 is the EU's implementation of CARF for cross-border tax information exchange. While they address different tax bases (CARF reporting vs GST consumption tax), both are part of jurisdictions implementing internationally-coordinated tax treatments of crypto. Reinforcing rather than conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:cb25f3c4bb21bc62b2c98b14", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "regime_b": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "NIS 2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "evidence_b": [{"chunk_id": "20d29e9c5300ae10::265::c962", "source_doc": "NIS2_Directive_EU_2022-2555.pdf", "page": 17, "passage": "(83) Essential and important entities should ensure the security of the network and information systems which they use\nin their activities. Those systems are primarily private network and information systems managed by the essential\nand important entities' internal IT staff or the security of which has been outsourced. The cybersecurity risk-\nmanagement measures and reporting obligations laid down in this Directive should apply to the relevant essential\nand important entities regardless of whether those entities maintain their network and information systems\ninternally or outsource the maintenance thereof."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLD 6 AML supervisory directive and EU NIS 2 horizontal cybersecurity directive operate in disjoint regulatory domains at the obligation level. AML supervisory directive vs horizontal cybersecurity directive — different regulatory purposes. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:43:21Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:26cd39fa122250d0ad007036", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "6d8a84a9f3d6e9e4::480::ac46", "source_doc": "Guidelines_to_MAS_Notice_SFA04-N02_2025.pdf", "page": 5, "passage": "2 The FSM Sanctions Regulations include the regulations issued under section 192 read with sections 15(1)(b) and 219(d)\nof the FSM Act. Please refer to the following link for the FSM Sanctions Regulations:\nhttps://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions/regulations-for-targeted-financial-\nsanctions. Currently, the relevant FSM Sanctions Regulations are those relating to the Democratic People's Republic of\nKorea and Iran. concerns. Other support functions such as operations, human resource or\ntechnology also play a role to help mitigate the ML/TF risks that the CMI faces. The AML/CFT compliance function is typically the contact point regarding all\nAML/CFT issues for domestic and foreign authorities, including supervisory\nauthorities, law enforcement authorities and financial intelligence units.\n1-4-14 As the third line of defence, the CMI's internal audit function or an equivalent\nfunction plays an important role in independently evaluating the AML/CFT risk\nmanagement framework and controls for purposes of reporting to the audit\ncommittee of the CMI's board of directors, or a similar oversight body."}, {"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "The evidence for Regime A (AU_APRA_CPS230) focuses on operational resilience, business continuity, and the management of service providers to ensure critical operations continue through disruptions. The evidence for Regime B (SG_MAS_AML_GENERAL) focuses on Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) obligations, specifically regarding targeted financial sanctions, the role of the compliance function, and the supervision of Digital Payment Token (DPT) providers. The obligations in Regime A relate to maintaining operational continuity and managing service provider risks, while the obligations in Regime B relate to financial crime compliance and sanctions screening. These are distinct regulatory domains that do not impose conflicting requirements on the same operational activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:26:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:ae9b1b6ff9363166038f85b1", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "14cb9eb911d15322::42b::fe23", "source_doc": "2023_Response_PS_Regulations_Amendments.pdf", "page": 22, "passage": "LTD Question 1. MAS seeks comments on the proposed amendments to the Payment Services\nRegulations.\n1. The term safeguarding institution needs to be defined for the purposes of\nRegulation16C. Since DPTSP can self custodize it would be good to have a clear\ndefinition of safeguarding customer's assets. The term \"safeguarding\" is also not\nused/defined in Securities and Futures Act or in the Securities and Futures\n(licensing and conduct of business) regulations in the context of customer\nassets.\n2. It is not clear in these amendments whether a PSA license is a blanket license\nthat will allow the licensee to conduct all of the digital payment token services\n(i.e. broking dealing in DPT, DPT Exchange, DPT Custody) under one PSA license 2 April 2024 | 26\nor would a licensee be granted a PSA license for specific digital payment token\nservices? Trying to draw an analogy here from the Capital Market Services\nLicense (CMSL) where each CMSL holder is given a license outlining the activities\nthat they can do under the CMSL license.\n8 Interactive Brokers Question 1."}, {"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}], "rationale": "The EU_MAR passages establish a regulatory framework for market abuse, specifically requiring market operators and investment firms to establish arrangements for preventing and detecting insider dealing and market manipulation (chunk_ids 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The SG_PSA_GENERAL passages discuss the licensing of Digital Payment Token Services (DPT) and the regulatory scope of the Payment Services Act, including the definition of safeguarding institutions and the application of a PSA license to specific services (chunk_ids 14cb9eb911d15322::42b::fe23, 321e082bdbe732d3::309::b080). The obligations in EU_MAR relate to the conduct of market participants and the prevention of market abuse, while the obligations in SG_PSA_GENERAL relate to the licensing and operational scope of payment service providers for digital tokens. These are distinct regulatory domains; there is no specific obligation in EU_MAR that pushes against a specific obligation in SG_PSA_GENERAL. Therefore, the regimes are in non_conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:44:04Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9f05ab998ed912a6467f2231", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::34a::74e3", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 11, "passage": "33. Article 109(1)(d) MiCA requires ESMA to establish a register of CASPs which must be\npublicly available on its website and be updated on a regular basis. Article 109(5) MiCA\nspecifies the information which the register must contain, including the name, legal form\nand legal entity identifier of the CASP and, where applicable, of the where applicable, of\nthe CASP's branches and the list of crypto-asset services provided by the CASP. To\nensure that an application for authorisation also contains all information required for the\nfuture ESMA public register of CASPs, ESMA proposes to include a few additional\ninformation requirements of limited extent to reflect the requirements of Article 109(5) of\nMiCA in the draft RTS on the application for authorisation as a CASP.\n\n4 Complaints-handling procedures of crypto-asset service\nproviders"}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "The EU MiCA passages focus on the application process for authorisation as a Crypto-Asset Service Provider (CASP), the information required for applications, and the establishment of a public register of CASPs (chunk_ids c51ad46265cea4e5::147::6214, c51ad46265cea4e5::34a::74e3). The Singapore MAS passages focus on the submission of consultation comments, the development of the digital asset ecosystem, and the prudential treatment and capital requirements for Stablecoin Issuers (chunk_ids 3d9b3d4849297e91::3c6::7b85, 7c04f2a0bd85290a::449::02f2). The obligations in MiCA regarding CASP authorisation and registration do not directly oppose the MAS prudential capital requirements for stablecoin issuers; rather, they regulate different aspects of the crypto-asset landscape (authorisation vs. prudential capital). Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.84, "record_type": "non_conflict", "pair_id": "non_conflict:a6a31d12e6b01b9dc70aca48", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AML/CTF Act + Rules"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "MAS AML/CFT Notices"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}, {"chunk_id": "be249e4e669b5817::468::ecb3", "source_doc": "Customer identification and verification.pdf", "page": null, "passage": "'@ Australian Government\n\" AUSTRAC Customer identification\nand verification Home / Business / Core guidance / Customer identification and verification As a reporting entity, you must identify and know your customers. Your customer identification procedures - know your customer (KYC) procedures -\nmust be documented in Part B of your AML/CTF program. All AML/CTF programs must\ninclude a Part B program. To identify, mitigate and manage money laundering and terrorism financing (ML/TF) risk,\nyou need ongoing customer due diligence processes. This includes developing and\ndocumenting an enhanced customer due diligence program and a transaction\nmonitoring program in Part A of your AML/CTF program. Holders of an Australian Financial Services Licence (AFSL) who arrange for their\ncustomers to receive a designated service, and do not provide any other designated\nservices, do not have to have a Part A program. Customer identification and ongoing customer due diligence processes will help you\nidentify unusual transactions and behaviour, to identify and manage high-risk customers\nand report suspicious matters when appropriate."}], "evidence_b": [{"chunk_id": "39886a6842407c92::319::727a", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 31, "passage": "11.8 All wire transfer originator and beneficiary information collected by the ordering institution\nshall be documented.\n\n11.9 Where the ordering institution is unable to comply with the requirements in paragraphs\n11.3 to 11.8, it shall not execute the wire transfer.\nResponsibility of the Beneficiary Institution\n\n11.10 A bank that is a beneficiary institution shall take reasonable measures, including post-\nevent monitoring or real-time monitoring where feasible, to identify cross-border wire\ntransfers that lack the required wire transfer originator or required wire transfer beneficiary\ninformation.\n\n11.11 For cross-border wire transfers, a beneficiary institution shall identify and verify the\nidentity of the wire transfer beneficiary if the identity has not been previously verified."}, {"chunk_id": "61149885d6ded889::6c9::01d7", "source_doc": "MAS_Notice_824_FinanceCompanies_2025-06-30.pdf", "page": 32, "passage": "11.7 In a domestic wire transfer, every finance company that is an ordering institution shall\neither -\n(a) include in the message or payment instruction that accompanies or relates to the\nwire transfer the following:\n(i) the name of the wire transfer originator;\n(ii) the wire transfer originator's account number (or unique transaction\nreference number where no account number exists); and\n(iii) any of the following\n(A) the wire transfer originator's:\n(1) residential address; or\n(2) registered or business address, and if different, principal place\nof business,\nas may be appropriate;\n(B) the wire transfer originator's unique national identification number\n(such as an identity card number, birth certificate number or passport\nnumber, or where the wire transfer originator is not a natural person,\nthe incorporation number or business registration number);\n(C) the date and place of birth, incorporation or registration of the wire\ntransfer originator (as may be appropriate); or\n(b) include only the wire transfer originator's account number (or unique transaction\nreference number where no account number exists), provided -\n(i) that these details will permit the transaction to be traced back to the wire\ntransfer originator and wire transfer beneficiary;\n(ii) the ordering institution shall provide the wire transfer originator information\nset out in paragraph 11.7(a) within 3 business days of a request for such\ninformation by the beneficiary institution, by the Authority or other relevant\nauthorities in Singapore; and\n(iii) the ordering institution shall provide the wire transfer originator information\nset out in paragraph 11.7(a) immediately upon request for such information\nby law enforcement authorities in Singapore."}], "rationale": "AUSTRAC AML/CTF and MAS AML/CFT Notices are parallel implementations of FATF standards in two distinct jurisdictions, with separate regulated populations and separate reporting channels. A firm operating in both jurisdictions complies with both. The two regimes are equivalence candidates (and labelled as such in equivalences.jsonl) rather than conflicting. No obligation in one points against any obligation in the other.", "would_conflict_if": ["Two regulators asserted jurisdiction over the same firm with contradictory record-retention or reporting demands — outside the conflict-detection scope here."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:15:09Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9c251ec0a04a137eeb9497c8", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The EU PSD2 passages regulate the technical and operational requirements for payment services, specifically strong customer authentication (SCA) and security credentials (chunk_ids adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b). The SG Foundational Legislation passages discuss the regulation of digital tokens, ICOs, and the Payment Services Act (PS Act) in the context of securities and AML/CFT compliance (chunk_ids b49627bb889ef1d9::3ef::7168, d6f4be6b9d136778::467::12af). The obligations in the EU regime relate to the authentication of payment transactions, while the SG regime addresses the authorisation and conduct of digital token issuers and exchanges. These are distinct regulatory domains; there is no specific obligation in the EU PSD2 that directly conflicts with the obligations in the Singapore Payment Services Act or MAS directives regarding digital tokens."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:25:18Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:8cf0a7755557c68b7bed21bd", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "Regime A (INT_BASEL_CRYPTO) regulates capital requirements and risk-weighting for bank exposures to financial institutions, including securities firms and central counterparties. Regime B (SG_FSMA_DTSP) regulates the licensing and conduct of Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022. The obligations in Regime A relate to prudential supervision and capital adequacy for banks, while the obligations in Regime B relate to the licensing and operational conduct of DTSPs. The passages confirm that these regimes govern distinct entities and activities (banks vs. DTSPs) and do not impose conflicting obligations on the same subject matter. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T06:30:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.7, "record_type": "conflict", "pair_id": "conflict:62ec2e3e0b8576c48323ef6c", "label": "conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "ASIC crypto-asset guidance (INFO 225 / RG 282)"}, "regime_b": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU Treasury Digital Asset Platforms proposals"}, "conflict_type": "interpretive_fact_sensitive", "severity": "low", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::418::88fb", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "An update in 2018 introduced the term 'crypto-asset' into INFO 225.\n4 INFO 225 was updated in 2019, adding further information and broader\nconsideration of when crypto-assets and related products may be financial\nproducts, and can interact with the existing financial services laws.\n5 It was further updated in 2021 to add good practice guidance for investment\nproducts providing exposure to crypto-assets. This followed Consultation\n© Australian Securities and Investments Commission December 2024 Page 6 Paper 343 Crypto-assets as underlying assets for ETPs and other investment\nproducts (CP 343) and Report 705 Response to submissions on CP 343\nCrypto-assets as underlying assets for ETPs and other investment products\n(REP 705). The title was changed at that time to Information Sheet 225\nCrypto-assets to more accurately reflect the scope of the guidance already\nincluded. The need to update INFO 225\n6 The digital asset market has continued to develop significantly in recent\nyears, with new digital asset products and services being offered."}, {"chunk_id": "0f9405790995711f::3de::a78f", "source_doc": "RG_282_Exchange_Traded_Products.pdf", "page": 45, "passage": "RG 282.139 For crypto-assets that are also financial products, market operators should be\nsatisfied that there is a pricing mechanism for those crypto-assets which is as\nrobust and transparent as those used by non-crypto-assets of that class of\nfinancial product.\nAdmission and monitoring standards\n\nRG 282.140 For all crypto-asset ETPs, we expect market operators to be satisfied that the\nstructure and operation of the product appropriately account for the unique\ncharacteristics and risks of crypto-assets. We expect market operators to\nconsider the good practices for crypto-asset investment products set out in\nINFO 225 and verify, as part of the admission process, that the structure and\noperation of the product seeking admission are consistent with the good\npractices outlined in INFO 225. It is also good practice for market operators\nto periodically assess whether admitted crypto-asset ETPs are maintaining an\nappropriate structure and operation.\nDisclosure of portfolio holdings"}], "evidence_b": [{"chunk_id": "e6bb47e92e88e16c::37a::29f6", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 12, "passage": "16. After token mapping, licensing and custody reforms are the logical next step for crypto reforms\nin Australia. The identification of appropriate obligations and operational standards for crypto\nasset service providers and how they safe-keep assets for customers is a key step for consumer\nprotection; ensuring consumers do not lose assets to avoidable business failure or misuse of\nassets by the provider.\n\n17. The Government will release a consultation paper proposing a licensing and custody framework\nfor crypto asset service providers in mid-2023 to allow for sufficient consultation prior to the\nintroduction of legislation. The paper will reflect ongoing work and consultation in this area and\nleverage the findings from the token mapping exercise. The responses to the following\nquestions will help inform the general direction of future policy and potential consumer\nprotections."}, {"chunk_id": "e6bb47e92e88e16c::2af::609f", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 39, "passage": "117. The token mapping framework defines the concepts of 'tokens', 'token systems' and 'functions'.\nA crypto token performs the record keeping role. It is analogous to a physical token or an entry\nin a registry. A token system is the business or social protocol, or mechanism. It is the steps\ntaken to perform a function in relation to crypto tokens. A function is the product or benefit\nprovided by a token system.\nInsights\n\n118. The crypto ecosystem is not a homogenous industry sector and crypto assets are not a\nhomogenous asset class. The process of assessing crypto related products against the functional\nperimeter is no different than the process for assessing any other product."}, {"chunk_id": "550958b067dc6726::51b::b09b", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 6, "passage": "5 KordaMentha, 'Token mapping: Response to Treasury consultation paper', March 2023. Introduction | 3 laws, digital asset platforms that do not deal in financial products are not subject to financial services\nlaws. The Government intends to introduce a regulatory framework aimed at addressing the significant risks\nand potential harms associated with digital asset platforms, while fostering innovation and safe usage\nof digital assets and distributed ledger technology. The framework outlined in this paper proposes to\nregulate digital asset platforms within the existing Australian financial services laws, while ensuring all\nconsumers and businesses have the opportunity to safely explore and share in any benefits of the\ntechnology. Key terms and concepts used throughout this paper\nUnderstanding the policy problem and the proposed regulatory solution requires an understanding of\nseveral key concepts and terms that are used throughout this paper. These concepts and terms aim to\nreduce the complexity of the paper's content, which necessarily covers topics across industries,\ntechnologies, and regulatory frameworks. They include some broad generalisations for descriptive\nconvenience and some precise technical descriptions for topics stakeholders have identified as causing\nregulatory uncertainty."}], "rationale": "ASIC's INFO 225 / RG 282 architecture turns on whether a given crypto-asset is a 'financial product' under the Corporations Act. Treasury's Token Mapping consultation and the DAP Proposal are explicitly designed around resolving that classification question — Treasury notes (DAP Proposal page 3) that 'digital asset platforms that do not deal in financial products are not subject to financial services laws'. Whether any particular token falls inside ASIC's licensing perimeter, or outside it (and within Treasury's proposed parallel DAP regime), depends on facts about the token's function — consumptive vs investment, pooled vs direct, payment-token-like vs security-like — that are themselves the subject of the Token Mapping framework. This is interpretive_fact_sensitive in the strict sense: the typology is the conflict.", "compliant_paths": ["Apply ASIC's existing financial-product tests case-by-case until Token Mapping + DAP legislation crystallises a clear taxonomy."], "out_of_scope_assumptions": ["Treasury DAP framework is at consultation/proposal stage and may evolve before enactment."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:3d62610c9965059d22310c5d", "label": "conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "rationale": "AU_PRIVACY (APP 8 cross-border disclosure of personal information) and EU_AMLR_TFR (EU AML regulation extending AML/CFT to CASPs and mandating originator/beneficiary information for crypto transfers — Regulation 2023/1113). When EU CASPs send crypto value to AU counterparties, the TFR's mandated personal-data sharing engages APP 8 restrictions on the AU side (and vice versa). Operationally resolvable via APP 6.2(b) (use/disclosure required or authorised by law) plus APP 8.2(d) permitted general situation, layered with GDPR Chapter V mechanisms for the EU side. Same cross-jurisdictional AML-privacy shape.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:54Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:1d84b50049d1812cf4b0d9d0", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DAC 8 (crypto tax)"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "Market Abuse Regulation"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::4d9::6684", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 25, "passage": "B. Due diligence procedures for Entity Crypto-Asset Users\nThe following procedures apply for the purpose of determining whether the Entity Crypto-Asset User is a Reportable\nUser or an Entity, other than an Excluded Person or an Active Entity, with one or more Controlling Persons who are\nReportable Persons.\n1. Determine whether the Entity Crypto-Asset User is a Reportable Person. (a) When establishing the relationship with the Entity Crypto-Asset User, or with respect to Pre-existing Entity\nCrypto-Assets Users by 1 January 2027, the Reporting Crypto-Asset Service Provider shall obtain a self-\ncertification that allows the Reporting Crypto-Asset Service Provider to determine the Entity Crypto-Asset\nUser's residence(s) for tax purposes and confirm the reasonableness of such self-certification based on the\ninformation obtained by the Reporting Crypto-Asset Service Provider, including any documentation collected\npursuant to Customer Due Diligence Procedures. If the Entity Crypto-Asset User certifies that it has no\nresidence for tax purposes, the Reporting Crypto-Asset Service Provider may rely on the place of effective\nmanagement or the address of the principal office to determine the residence of the Entity Crypto-Asset User."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::1bd::d04c", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 14\nProhibition of insider dealing and of unlawful disclosure of inside information\nA person shall not:\n(a) engage or attempt to engage in insider dealing;\n(b) recommend that another person engage in insider dealing or induce another person to engage in insider dealing; or\n(c) unlawfully disclose inside information.\n\nArticle 15\nProhibition of market manipulation\nA person shall not engage in or attempt to engage in market manipulation."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU DAC 8 crypto-asset tax-reporting directive and EU Market Abuse Regulation operate in disjoint regulatory domains at the obligation level. Crypto-tax reporting vs market abuse regulation — disjoint subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:19:24Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:d41e089d39337cba670a2585", "label": "conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}], "rationale": "AU_ATO_CRYPTO (ATO crypto-asset tax framework — reporting and recordkeeping on AU taxpayers' crypto-asset disposals and holdings, including those involving EU counterparties or operators) and EU_GDPR (Article 44+ cross-border data transfer restrictions). When AU exchanges and crypto-asset operators serve EU-resident customers or hold EU-side data, ATO reporting can require transmitting personal data from the EU to AU. GDPR Chapter V restrictions engage. Operationally resolvable via GDPR Art. 6(1)(c) + Chapter V mechanism (adequacy, SCCs, or Art. 49 derogation). Same conflict shape as DAC8 × PDPA, applied to AU-EU tax-reporting framework.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:43Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.82, "record_type": "conflict", "pair_id": "conflict:b3d280901e9d6ab202be7a26", "label": "conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "conflict_type": "structural_unresolved", "severity": "high", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "AU_TREASURY_DAP (Australia's proposed crypto-asset platform licensing) and SG_PSA_DPT (Singapore's Payment Services Act Digital Payment Token service licensing, under MAS PSN02). Both establish jurisdiction-specific licensing for entities providing crypto-asset / DPT services. Neither contains a transit pathway recognising the other's authorisation. Same structural-non-transit pattern as AU_DAP ↔ EU_MICA.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:50Z", "decision": "accept", "notes": "", "original_conflict_type": "structural_unresolved", "original_severity": "high", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:17:21Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:732fbd47fc3f8b6ba90f0c5e", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}, {"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "The EU MIFID2 passages regulate investment firms' obligations regarding product governance, suitability assessments, and client information disclosure (e.g., Article 1, Article 24, Article 25). The SG_FSMA_DTSP passages regulate the licensing and conduct of Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022, including the requirement to hold a licence and the definition of DTSPs. The obligations in MIFID2 relate to the suitability of financial instruments for clients, whereas the obligations in the SG regime relate to the licensing and risk management of digital token service providers. The two regimes regulate distinct domains of financial services conduct and licensing, with no specific obligation in one regime pushing against a specific obligation in the other. Therefore, the regimes are in non-conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:15:44Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:8dd4f3fcdb9f3c64e7cb8e7c", "label": "conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}, {"chunk_id": "0e996ae99839f19e::61d::14e5", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "23 Act 2012 2020Ed. Deemed consent by notification\n15A.-(1) This section applies to the collection, use or disclosure\nof personal data about an individual by an organisation on or after\n1 February 2021.\n[40/2020]\n(2) Subject to subsection (3), an individual is deemed to consent to\nthe collection, use or disclosure of personal data about the individual\nby an organisation if -\n(a) the organisation satisfies the requirements in\nsubsection (4); and\n(b) the individual does not notify the organisation, before the\nexpiry of the period mentioned in subsection (4)(b)(iii),\nthat the individual does not consent to the proposed\ncollection, use or disclosure of the personal data by the\norganisation.\n[40/2020]\n(3) Subsection(2)doesnotapplytothecollection,useordisclosure\nof personal data about the individual for any prescribed purpose.\n[40/2020]\n(4) For the purposes of subsection (2)(a), the organisation must,\nbefore collecting, using or disclosing any personal data about the\nindividual -\n(a) conduct an assessment to determine that the proposed\ncollection, use or disclosure of the personal data is not\nlikely to have an adverse effect on the individual;\n(b) take reasonable steps to bring the following information to\nthe attention of the individual:\n(i) theorganisation'sintentiontocollect,useordisclose\nthe personal data;\n(ii) the purpose for which the personal data will be\ncollected, used or disclosed;\n(iii) a reasonable period within which, and a reasonable\nmanner by which, the individual may notify the\norganisation that the individual does not consent to"}], "rationale": "EU_EMD2 (E-Money Directive 2 — EMI customer KYC for issuance and redemption, including AML/CFT obligations on EMI issuers) and SG_PDPA. EU EMIs serving SG-resident customers must collect identification data for issuance and may transmit to SG counterparties; PDPA restricts. Operationally resolvable via PDPA s.13(b) carve-out + SG MAS AML notice framework. Same KYC×privacy cross-jur conflict shape as the labelled EU TFR ↔ EU GDPR conflict.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:31Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:06:07Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:3969da88f23a7d367b59f630", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "evidence_b": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}, {"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The EU_EMD2 passages discuss the Digital Operational Resilience Act (DORA) and financial rules for the European Union Authority, focusing on digital resilience and financial administration. The MAS_TRM passages discuss the Monetary Authority of Singapore's (MAS) response to feedback on guidelines for licensees, specifically the TRM Guidelines, Fit and Proper Criteria, and Business Continuity Management. The obligations in EU_EMD2 regarding digital operational resilience and financial rules do not overlap with the obligations in MAS_TRM regarding internal processes for inaccurate representations, sector-specific competencies, and principles-based risk assessments. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:41:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:0ac2c2848bff92302519cd5e", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "rationale": "The Australian regime (AU_ATO_CRYPTO) focuses on the taxation and regulatory mapping of crypto assets, specifically regarding their adoption and classification (chunk_id e6bb47e92e88e16c::567::36c4). The EU regime (EU_NIS2) addresses cybersecurity measures for operators of essential services and digital operational resilience in the financial sector, specifically regarding access controls and cryptography policies (chunk_id 3c9eb3a25c93f394::474::4786). The obligations in these regimes regulate distinct domains—taxation and classification versus cybersecurity and resilience—resulting in no overlap or conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:33:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b6caa3a89f1aba0db6f4e094", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}], "rationale": "The Australian regime (AU_ATO_CRYPTO) focuses on tax compliance and the mapping of crypto assets, specifically noting the tax treatment of over 1 million Australians holding crypto (chunk_id e6bb47e92e88e16c::567::36c4). The Singapore regime (SG_PSA_GENERAL) focuses on the licensing and regulatory scope of Digital Payment Token (DPT) services under the Payment Services Act, including transitional exemptions for entities currently operating DPT services (chunk_id 321e082bdbe732d3::309::b080). The passages describe distinct regulatory domains: one governing tax obligations and the other governing financial services licensing and conduct. There is no evidence of a specific obligation in one regime that directly conflicts with a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:0ea43f7a31e04b2a4a18be9d", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "SG_MAS_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "a82833dc0f7ca903::5f1::735d", "source_doc": "Outsourcing_Guidelines_2018.pdf", "page": 25, "passage": "5.10.2 Material outsourcing arrangements with service providers located outside Singapore\nshould be conducted in a manner so as not to hinder MAS' efforts to supervise the Singapore\nbusiness activities of the institution (i.e., from its books, accounts and documents) in a timely\nmanner, in particular:\n(a) An institution should, in principle, enter into outsourcing arrangements only\nwith service providers operating in jurisdictions that generally uphold\nconfidentiality clauses and agreements.\n\n(b) An institution should not enter into outsourcing arrangements with service\nproviders in jurisdictions where prompt access to information by MAS or\nagents appointed by MAS to act on its behalf, at the service provider, may\nbe impeded by legal or administrative restrictions. An institution must at\nleast commit to retrieve information readily from the service provider\nshould MAS request for such information. The institution should confirm in\nwriting to MAS, that the institution has provided, in its outsourcing\nagreements, for MAS to have the rights of inspecting the service provider,\nas well as the rights of access to the institution and service provider's\ninformation, reports and findings related to the outsourcing arrangement,\nas set out in paragraph 5.9.\n(c) An institution should notify MAS if any overseas authority were to seek\naccess to its customer information or if a situation were to arise where the\nrights of access of the institution and MAS set out in paragraph 5.9, have\nbeen restricted or denied."}], "rationale": "AU_APRA_CPS230 (APRA Prudential Standard CPS 230 — Operational Risk Management including service-provider arrangements) and SG_MAS_OUTSOURCING (MAS Outsourcing Guidelines — material outsourcing arrangements with third-party service providers). Both address third-party / outsourcing risk for regulated financial entities in their respective jurisdictions. Reinforcing concerns — entities operating across both face complementary outsourcing-management duties."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:46:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:656936fa25f79ae4add6adc1", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + TFR"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "Market Abuse Regulation"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}, {"chunk_id": "d7502c011527b67c::1a0::faa6", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 24, "passage": "Article 19\nRetention of information on the originator and the beneficiary accompanying the transfer\nIntermediary crypto-asset service providers shall ensure that all the information received on the originator and the\nbeneficiary that accompanies a transfer of crypto-assets is transmitted with the transfer and that records of such\ninformation are retained and made available on request to the competent authorities."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::1bd::d04c", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 14\nProhibition of insider dealing and of unlawful disclosure of inside information\nA person shall not:\n(a) engage or attempt to engage in insider dealing;\n(b) recommend that another person engage in insider dealing or induce another person to engage in insider dealing; or\n(c) unlawfully disclose inside information.\n\nArticle 15\nProhibition of market manipulation\nA person shall not engage in or attempt to engage in market manipulation."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "rationale": "AMLR/TFR addresses AML/CFT — customer due diligence, information accompanying transfers, suspicious-transaction reporting. The Market Abuse Regulation addresses market abuse — insider dealing, unlawful disclosure of inside information, market manipulation. The two regimes apply to overlapping populations (some EU obliged entities are also in-scope of MAR), but the subject matters are disjoint. No AMLR/TFR obligation pushes against any MAR obligation. Hard negative.", "would_conflict_if": ["MAR Art 16 STOR (suspicious transaction or order report) regime conflicted with AMLR SMR confidentiality — in practice both regimes have parallel reporting channels and confidentiality protections."]}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.84, "record_type": "non_conflict", "pair_id": "non_conflict:4e5cfcc7b1b0f59c34f6a26e", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + Transfer of Funds Regulation"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}, {"chunk_id": "c4024f4c4c1616cc::603::a3b7", "source_doc": "AMLR_Regulation_EU_2024-1624.pdf", "page": 68, "passage": "Article 37\nSpecific enhanced due diligence measures for cross-border correspondent relationships for crypto-asset service\nproviders\n1. By way of derogation from Article 36, with respect to cross-border correspondent relationships involving the\nexecution of crypto-asset services, with a respondent entity not established in the Union and providing similar services,\nincluding transfers of crypto-assets, crypto-asset service providers shall, in addition to the customer due diligence measures\nlaid down in Article 20, when entering into a business relationship, be required to:\n(a) determine if the respondent entity is licensed or registered;\n68/111 ELI: http://data.europa.eu/eli/reg/2024/1624/oj EN\n(b) gather sufficient information about the respondent entity to understand fully the nature of the respondent's business\nand to determine from publicly available information the reputation of the entity and the quality of supervision;\n(c) assess the respondent entity's AML/CFT controls;\n(d) obtain approval from senior management before establishing the new correspondent relationship;\n(e) document the respective responsibilities of each party to the correspondent relationship;\n(f) with respect to payable-through crypto-asset accounts, be satisfied that the respondent entity has verified the identity of,\nand performed ongoing due diligence on, the customers having direct access to accounts of the correspondent entity,\nand that it is able to provide relevant customer due diligence data to the correspondent entity, upon request."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::4d0::eb51", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 28, "passage": "Authorisation as a crypto-asset service provider pursuant to Article 59 is not required for providing custody and\nadministration of crypto-assets on behalf of clients or for providing transfer services for crypto-assets in relation to\ncrypto-assets whose offers to the public are exempt pursuant to paragraph 3 of this Article, unless:\n(a) there exists another offer to the public of the same crypto-asset and that offer does not benefit from the exemption;\nor\n(b) the crypto-asset offered is admitted to a trading platform.\n6. Where the offer to the public of the crypto-asset other than an asset-referenced token or e-money token concerns\na utility token providing access to goods and services that do not yet exist or are not yet in operation, the duration of\nthe offer to the public as described in the crypto-asset white paper shall not exceed 12 months from the date of\npublication of the crypto-asset white paper.\n7. Any subsequent offer to the public of the crypto-asset other than an asset-referenced token or e-money token shall\nbe deemed a separate offer to the public to which the requirements of paragraph 1 apply, without prejudice to the\npossible application of paragraph 2 or 3 to the subsequent offer to the public."}, {"chunk_id": "491a2f0014d56ffb::5dc::7b39", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 84, "passage": "Article 65\nCross-border provision of crypto-asset services\n1.\nA crypto-asset service provider that intends to provide crypto-asset services in more than one Member State shall\nsubmit the following information to the competent authority of the home Member State:\n(a) a list of the Member States in which the crypto-asset service provider intends to provide crypto-asset services;\n(b) the crypto-asset services that the crypto-asset service provider intends to provide on a cross-border basis;\n(c) the starting date of the intended provision of the crypto-asset services;\n(d) a list of all other activities provided by the crypto-asset service provider not covered by this Regulation.\n2.\nThe competent authority of the home Member State shall, within 10 working days of receipt of the information\nreferred to in paragraph 1, communicate that information to the single points of contact of the host Member States, to\nESMA and to EBA.\n3.\nThe competent authority of the Member State that granted authorisation shall inform the crypto-asset service\nprovider concerned of the communication referred to in paragraph 2 without delay.\n4.\nThe crypto-asset service provider may begin to provide crypto-asset services in a Member State other than its\nhome Member State from the date of receipt of the communication referred to in paragraph 3 or at the latest from the\n15th calendar day after having submitted the information referred to in paragraph 1.\nCHAPTER 2\nObligations for all crypto-asset service providers"}], "rationale": "Both regulations apply to EU crypto-asset service providers but on non-overlapping obligation surfaces. MiCA is the market-conduct and authorisation regime (CASP authorisation, white papers for ART/EMT, cross-border passporting under Art. 65). The AMLR/TFR adds AML/CFT obligations on the same CASPs: enhanced CDD for cross-border crypto relationships (AMLR Art. 37) and travel-rule information transmission (TFR Arts. 14–21). A CASP must comply with both, and the requirements are layered rather than opposing — MiCA tells you who can operate, AMLR/TFR tells you what AML controls you must apply once you do.", "would_conflict_if": ["MiCA Title V exemptions ever contradicted AMLR scope (e.g. exempted a service that AMLR captures as an 'obliged entity'); current text aligns the scopes via cross-referencing."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:49:52Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:6f428350daf44331dbafcc91", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "a0d157539d5c8040::2fc::beb4", "source_doc": "FinalReport_Market_Abuse_Guidelines_MiCA.pdf", "page": 6, "passage": "2 Background and Legal Basis\nArticle 92 (3) of MiCA:\nIn order to ensure consistency of supervisory practices under this Article, ESMA shall by 30\nJune 2025 issue guidelines in accordance with Article 16 of Regulation (EU) No 1095/2010 on\nsupervisory practices among the competent authorities to prevent and detect market abuse, if\nnot already covered by the regulatory technical standards referred to in paragraph 2.\n\n1. To promote confidence in markets in crypto-assets and ensure their integrity, Title VI of\nMiCA lays down rules on prevention and prohibition of market abuse involving crypto\nassets.\n\n2. Article 92(1) of MiCA requires any PPAET in crypto-assets to have in place effective\narrangements, systems and procedures to prevent and detect market abuse."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}], "rationale": "The EU_MICA passages discuss the prevention of market abuse involving crypto-assets and the licensing requirements for crypto-asset service providers (chunk_id a0d157539d5c8040::2fc::beb4). The FATF_R16 passages focus on global anti-money laundering (AML) and counter-terrorist financing (CFT) standards, specifically guidance on digital identity and red flag indicators for virtual assets (chunk_id 5d489619a0fb9ecf::377::a91e). The obligations in MiCA regarding market abuse prevention and licensing do not directly oppose the FATF's AML/CFT obligations; rather, they operate in complementary domains to ensure the integrity and security of crypto-asset markets."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:19:09Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:3b90d1a79e8e03f717dda019", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::5e6::a0b1", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "Initial views from consultation paper\n• Consultation paper focussed on • Stakeholders noted the complexity\nmarket licensing, custody and token of introducing new regulation\nmapping\n• Most stakeholders agreed that\n• Divergent views among many issues there is a need for custody\nregulation\n• Most agree that self-regulation is\nnot appropriate - Hard to implement detailed standards\nas each custodian operates differently\n• Differing views about creating\n- Capital requirements, insurance and\nbespoke regime or using the Corps\nliability for loss needs to be quite\nAct\nspecific\n- Sophisticated or larger stakeholders\n- No meaningful support for a domestic\nprefer more rigorous regulation (Corps\nlocation requirement. Act). Key terms and concepts\n• Blockchain • Crypto assets\n- A digital ledger comprised of - A useful blanket term that covers on-\nunchangeable, digitally recorded data chain assets: cryptocurrencies, NFTs,\nin packages called blocks. and other, still emerging, products.\n- Each block is 'chained' to the next\nblock using a cryptographic signature.\n• Web3 / Web 3.0\n- Ethereum is a public blockchain, open\n- Web3, or Web 3.0, are terms used\nto the world; its digital ledger is\nsynonymously with \"the decentralized\ndistributed, or synced, between many\nweb\" and are often used to refer,\nnodes; these nodes arrive at\nbroadly, to the blockchain and\nconsensus regarding whether a\ndecentralized technology ecosystems\ntransaction is valid before encrypting a\nas a whole.\nnumber of transactions into a block"}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}, {"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "The evidence from AU_CORPS_ACT focuses on the interaction of the Corporations Act with the Australian Charities and Not-for-profits Commission Act, detailing specific provisions regarding company constitutions, director duties, and winding up (chunk_ids 0fc4f857c226f510::375::66b5, c2e00b4f25de0d0c::371::2e15). It also contains a consultation paper discussing market licensing and custody regulation for crypto assets (chunk_id d75262e404517e0c::5e6::a0b1). The evidence from SG_FSMA_DTSP focuses on the regulatory framework for Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022, including definitions, licensing requirements, and FATF-aligned AML/CFT standards (chunk_ids 20d526d712753652::404::80be, cc1be49e9cf8c821::2f4::ea8f). While both regimes address digital assets, the specific obligations cited in the SG_FSMA_DTSP passages (licensing, FATF alignment) do not directly contradict or override the specific provisions or interaction rules cited in the AU_CORPS_ACT passages. The regimes regulate different aspects of corporate governance and digital asset service provision without creating a specific, actionable conflict between the cited obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:3b3d7ca0372bb8b32167c945", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "INT_BASEL_CRYPTO (regime A) and SG_MAS_PRUDENTIAL_CRYPTO (regime B) both regulate prudential treatment of crypto-asset exposures. SG MAS is explicitly considering a risk-based capital framework for SCS issuers (B's passage) consistent with the Basel approach to bank exposures (A's passage). SG implements Basel as part of its prudential framework; the regimes reinforce each other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:03:44Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:22da44ba9f8f07ebf4c8726c", "label": "non_conflict", "regime_a": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "The EU regime regulates the solicitation of clients by third-country crypto-asset firms (reverse solicitation exemption), while the Singapore regime mandates AML/CFT training for life insurers and general AML/CFT due diligence for banks. The obligations in Regime A (marketing crypto-assets to clients who initiated the relationship) do not impose a specific negative constraint on the obligations in Regime B (training and due diligence). The Singapore obligations apply to life insurers and banks, whereas the EU obligations apply to crypto-asset service providers. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:33:39Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:41da6a8f0140335e64358510", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}, {"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "rationale": "The EU MICA Title IV EMT regime regulates the disclosure obligations of issuers of e-money tokens, specifically requiring the notification of crypto-asset white papers to competent authorities and ensuring the information provided is complete, fair, and clear (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e). The FATF R16 regime focuses on anti-money laundering and counter-terrorist financing (AML/CFT) standards and guidance, including digital identity and virtual assets (chunk_ids 5d489619a0fb9ecf::377::a91e, 85240528438654b9::396::417b). The obligations in the EU regime relate to the transparency and accuracy of marketing disclosures for token issuance, while the FATF regime addresses the systemic risks of money laundering and terrorist financing. These are distinct regulatory domains; the EU disclosure requirements do not impose specific AML/CFT obligations that conflict with FATF standards, nor do the FATF standards prescribe specific disclosure formats that would contradict the EU's detailed white paper requirements. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:44:21Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:f6aa938dc13cf83df79b8f0c", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DORA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::3d7::f935", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 15, "passage": "(68) To evaluate and monitor on a regular basis the ability of an ICT third party service provider to securely provide\nservices to a financial entity without adverse effects on a financial entity's digital operational resilience, several key\ncontractual elements with ICT third-party service providers should be harmonised. Such harmonisation should\ncover minimum areas which are crucial for enabling a full monitoring by the financial entity of the risks that could\nemerge from the ICT third-party service provider, from the perspective of a financial entity's need to secure its\ndigital resilience because it is deeply dependent on the stability, functionality, availability and security of the ICT\nservices received.\n\n(69) When renegotiating contractual arrangements to seek alignment with the requirements of this Regulation, financial\nentities and ICT third-party service providers should ensure the coverage of the key contractual provisions as\nprovided for in this Regulation."}, {"chunk_id": "85307f9e2a040982::4c8::ae53", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 25, "passage": "Article 3\nDefinitions\nFor the purposes of this Regulation, the following definitions shall apply:\n(1) 'digital operational resilience' means the ability of a financial entity to build, assure and review its operational integrity\nand reliability by ensuring, either directly or indirectly through the use of services provided by ICT third-party service\nproviders, the full range of ICT-related capabilities needed to address the security of the network and information\nsystems which a financial entity uses, and which support the continued provision of financial services and their\nquality, including throughout disruptions;\n(2) 'network and information system' means a network and information system as defined in Article 6, point 1, of\nDirective (EU) 2022/2555;\n(3) 'legacy ICT system' means an ICT system that has reached the end of its lifecycle (end-of-life), that is not suitable for\nupgrades or fixes, for technological or commercial reasons, or is no longer supported by its supplier or by an ICT\nthird-party service provider, but that is still in use and supports the functions of the financial entity;\n(4) 'security of network and information systems' means security of network and information systems as defined in"}], "rationale": "The AU Travel Rule passages discuss the implementation of FATF's 'Travel Rule' for digital currency exchanges and remittance providers, focusing on customer identification and transaction transparency obligations. The EU DORA passages define 'digital operational resilience' and 'ICT third-party risk management' requirements for financial entities. The obligations are distinct: one relates to AML/CTF transaction monitoring and beneficial ownership visibility, while the other relates to the security and resilience of ICT systems and third-party service providers. There is no specific obligation in AU Travel Rule that pushes against a specific obligation in EU DORA. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:38:40Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:ee6e0eba646b444b51a53e7c", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DORA"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::3d7::f935", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 15, "passage": "(68) To evaluate and monitor on a regular basis the ability of an ICT third party service provider to securely provide\nservices to a financial entity without adverse effects on a financial entity's digital operational resilience, several key\ncontractual elements with ICT third-party service providers should be harmonised. Such harmonisation should\ncover minimum areas which are crucial for enabling a full monitoring by the financial entity of the risks that could\nemerge from the ICT third-party service provider, from the perspective of a financial entity's need to secure its\ndigital resilience because it is deeply dependent on the stability, functionality, availability and security of the ICT\nservices received.\n\n(69) When renegotiating contractual arrangements to seek alignment with the requirements of this Regulation, financial\nentities and ICT third-party service providers should ensure the coverage of the key contractual provisions as\nprovided for in this Regulation."}, {"chunk_id": "85307f9e2a040982::5f2::974e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 23, "passage": "Article 1\nSubject matter\n1. In order to achieve a high common level of digital operational resilience, this Regulation lays down uniform\nrequirements concerning the security of network and information systems supporting the business processes of financial\nentities as follows:\n(a) requirements applicable to financial entities in relation to:\n(i) information and communication technology (ICT) risk management;\n(ii) reporting of major ICT-related incidents and notifying, on a voluntary basis, significant cyber threats to the\ncompetent authorities;\n(iii) reporting of major operational or security payment-related incidents to the competent authorities by financial\nentities referred to in Article 2(1), points (a) to (d);\n(iv) digital operational resilience testing;\n(v) information and intelligence sharing in relation to cyber threats and vulnerabilities;\n(vi) measures for the sound management of ICT third-party risk;\n(b) requirements in relation to the contractual arrangements concluded between ICT third-party service providers and\nfinancial entities;\n(c) rules for the establishment and conduct of the Oversight Framework for critical ICT third-party service providers when\nproviding services to financial entities;\n(d) rules on cooperation among competent authorities, and rules on supervision and enforcement by competent\nauthorities in relation to all matters covered by this Regulation.\n2. In relation to financial entities identified as essential or important entities pursuant to national rules transposing"}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}, {"chunk_id": "20d526d712753652::4b9::b812", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": 71, "passage": "(Please refer to paragraph 12 of the draft FSM Notice). The proposed requirements for Correspondent Account Services (CAS) in paragraph\n5.6 of the draft FSM Notice are both applicable and appropriate for the digital token\nservice provider (DTSP) sector. Given the inherent cross-border nature and rapid\ntransactions within digital token services, the FATF-aligned risk mitigation measures\nensure that DTSPs are aligned with global AML/CFT standards, providing a secure\nframework for correspondent services while addressing potential ML/TF risks. Applicability of Risk Mitigation Measures\nThe requirement for DTSPs to assess the suitability of financial institutions when\nproviding or receiving CAS, including evaluating their AML/CFT controls, is essential\nfor preventing potential misuse of these services. The dynamic and often cross-\njurisdictional interactions in digital token services make these standards particularly\nrelevant to ensuring consistent risk management. MAS could consider offering\nguidance on specific factors DTSPs should evaluate, such as transaction monitoring\ncapabilities and the jurisdiction's regulatory reputation, to better equip licensees in\napplying a comprehensive assessment."}], "rationale": "The EU DORA regime regulates the digital operational resilience and ICT risk management of financial entities and their third-party service providers (chunk_ids 85307f9e2a040982::3d7::f935, 85307f9e2a040982::5f2::974e). In contrast, the SG_FSMA_DTSP regime regulates the licensing and conduct of Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022 (chunk_ids cc1be49e9cf8c821::2f4::ea8f, 20d526d712753652::404::80be). While both regimes involve third-party risk and cross-border considerations, the SG regime focuses on licensing, AML/CFT compliance, and FATF alignment (chunk_ids cc1be49e9cf8c821::2f4::ea8f, 20d526d712753652::4b9::b812), whereas DORA focuses on ICT resilience and incident reporting. The obligations do not push against one another; they regulate distinct aspects of the financial ecosystem. Therefore, the relationship is non_conflict / different_domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:27:06Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:7afa1ebd838d5b41bc97dbeb", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "rationale": "The regimes regulate distinct domains. Regime A (AU_ATO_CRYPTO) concerns the taxation and regulation of crypto assets in Australia, including token mapping and consumer interest. Regime B (INT_BASEL_GENERAL) concerns the Basel III framework for banking regulation, specifically the leverage ratio and treatment of fiduciary assets. The cited passages from Regime A discuss crypto adoption and tax compliance, while the cited passages from Regime B discuss accounting frameworks for banks and leverage ratio exposure measures. There is no specific obligation in one regime that pushes against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:41:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:6818ca6a051287abbddaee6a", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "rationale": "The AU_TTR_THRESHOLD regime regulates the reporting of physical cash transactions exceeding A$10,000 to AUSTRAC (chunk_ids 6dfe4e63b9fb3c74::3bc::1a3f, 254ca2d92d196180::377::d0c6). The EU_PSD2 regime regulates the authentication of payment transactions, specifically strong customer authentication (SCA) for online and remote payments (chunk_ids adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b). The obligations are distinct: one is a financial crime reporting requirement for cash thresholds, while the other is a security and authentication standard for electronic payment initiation. There is no specific obligation in PSD2 that conflicts with the AUSTRAC TTR reporting obligation. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-05-26T01:13:52Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.65, "record_type": "conflict", "pair_id": "conflict:7b1c7facd95d29ea4c2777c8", "label": "conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "Basel d457 prudential crypto-asset"}, "regime_b": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 230"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "3d9b3d4849297e91::42d::6696", "source_doc": "2025_CP_Prudential_Treatment_Cryptoassets.pdf", "page": null, "passage": "Division 4: General Requirements for Group 2 Cryptoassets\nSub-division 1: RWA Calculation for Group 2b Instruments\n9A.4.1 For each Group 2 cryptoasset, to which a Reporting Bank has exposures arising\nfrom Group 2b instruments, the Reporting Bank must calculate the RWA by applying a risk\nweight of 1250% to the greater of the absolute value of the aggregate long exposures and\nthe absolute value of the aggregate short exposures to that cryptoasset928S as follows:\nRRRRAAii =1250%×mmmmee�mmaaee��aaeeAAHH eeeeeeeeeeeeeeeeii�,mmaaee��eeheeeemm eeeeeeeeeeeeeeeeii��\nwhere -\n(a) i refers to a Group 2 cryptoasset;\n(b) is the sum of long exposures to cryptoasset i; and\n∑aaeeAAHH eeeeeeeeeeeeeeeeii\n(c) is the sum of short exposures to cryptoasset i.\n∑eeheeeemm eeeeeeeeeeee eeeeii\n928R For example, the DLT.\n928S This treatment is intended to capture both credit and market risk, including CVA risk, and to ensure that\nthe Reporting Bank holds minimum risk-based capital at least equal in value to their exposures to Group 2\ncryptoassets arising from Group 2b instruments."}, {"chunk_id": "ffa7a3de1e0fc7f0::54e::336e", "source_doc": "d426.pdf", "page": 6, "passage": "2016.5 The Group 1 and Group 2 bank samples are not directly comparable due to different business\nmodels and different regional distribution of the samples, and hence the impacts on them are not uniform.\nHowever, effects vary across banks. Some banks will face increased capital requirements. Among\nGroup 1 banks the aggregate shortfall is €27.6 billion in CET1 capital and €90.7 billion in total capital. The\npredominant part of these shortfalls comes from G-SIBs. To put these shortfall numbers in perspective:\nprofit after tax for the same sample of banks in the concerned six-month reporting period (H2 2015)\namounted to €198.3 billion for Group 1 banks.6 Overall, the shortfall of the Group 2 banks in the sample\nwill be slightly reduced compared to current levels under fully phased-in national implementation of the\nBasel III framework as agreed up to January 2016.\nThe analysis also shows some evidence for a reduction in risk-weighted asset variability among\nthe Group 1 banks in the sample.\nOverview of results Table 1\nNumber of Change in Tier 1 MRC Change in CET1 Capital shortfalls combined\nbanks at the target level (%)1 capital ratio (€ billions)\nAll of which: (percentage\nCET1 Tier 1 Total\nrisk-based points)\nGroup 1 banks 71 -0.5 0.2 0.2 27.6 56.4 90.7\nOf which: G-SIBs 27 -1.4 -0.9 0.3 27.6 55.4 85.7\nGroup 2 banks 42 3.8 0.9 0.1 0.3 0.8 1.4"}], "evidence_b": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "rationale": "Basel d457 ('Prudential treatment of crypto-asset exposures', final standard, December 2022, effective 1 Jan 2026) sets the *international* capital and disclosure baseline for crypto-asset exposures of internationally active banks. APRA CPS 230 ('Operational Risk Management', effective 1 July 2025) imposes the *national* operational-risk, business-continuity and service-provider-management framework on APRA-regulated entities. The interaction is not contradictory — d457 speaks to capital adequacy, CPS 230 to operational resilience — but for AU ADIs taking on crypto-asset exposures via service providers or subsidiaries, the *combined* obligation set creates non-trivial compliance design questions: third-party-risk treatment under CPS 230 must align with the categorisation of Group 1a/1b/2a/2b exposures under d457; service-provider failure scenarios in CPS 230 BCP testing must account for the d457-mandated capital impacts. The tension is operationally resolvable: APRA's transposition of d457 (forthcoming as Prudential Standard APS 117 or equivalent) is expected to mirror Basel's categorisation, and CPS 230 explicitly contemplates integration with other prudential standards. Severity is low because the framework is designed for parallel application; the operational burden is real but not strategically destabilising.", "compliant_paths": ["Treat d457 as the prudential-treatment floor and align CPS 230 service-provider risk-management with the d457 categorisation of crypto exposures.", "Update CPS 230 BCP and incident-response playbooks to cover crypto-custody-provider failure scenarios consistent with d457's prudential treatment."], "out_of_scope_assumptions": ["Entity is APRA-regulated and internationally active enough to be in Basel d457 scope.", "APRA's transposition of d457 mirrors the Basel standard substantively (the current expectation)."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:36:47Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:6de38903608d0ee2f3ec0e42", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}], "rationale": "The EU regime (Regime A) regulates the information accompanying transfers of funds and crypto-assets to ensure traceability for AML/CFT purposes, specifically extending obligations to crypto-asset service providers (Recital 8). The Singapore regime (Regime B) is a consultation paper regarding the Payment Services Act and Digital Payment Token (DPT) services, focusing on licensing definitions and transitional exemptions for entities providing DPT services. The passages describe distinct regulatory frameworks: one establishing information requirements for cross-border transfers of value, and the other addressing the licensing and operational scope of DPT service providers within Singapore. There is no specific obligation in the EU regime that directly conflicts with a specific obligation in the Singapore regime; rather, they address different aspects of the digital asset ecosystem (information reporting vs. licensing scope)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:17:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:a51662828448182bec64048e", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3c8::f259", "source_doc": "d424.pdf", "page": 39, "passage": "67 See Annex 10 of Basel II (June 2006) for an overview of methodologies for the capital treatment of transactions secured by\nfinancial collateral under the standardised and IRB approaches.\n\n68 Alternatively, banks with appropriate supervisory approval may instead use the Internal Model Method to determine the\nexposure amount, taking into account collateral.\nBasel III: Finalising post-crisis reforms 35\n\n(ii) On-balance sheet netting\n\n135. Where banks have legally enforceable netting arrangements for loans and deposits that meet the\nconditions in paragraph 190 they may calculate capital requirements on the basis of net credit exposures\nas set out in that paragraph.\n(iii) Guarantees and credit derivatives\n\n136. Where guarantees or credit derivatives fulfil the minimum operational conditions set out in\nparagraphs 191 to 193, banks may take account of the credit protection offered by such credit risk\nmitigation techniques in calculating capital requirements."}, {"chunk_id": "32afd37cade34f84::168::f255", "source_doc": "d424.pdf", "page": 7, "passage": "4 Standards on capital requirements for banks' equity investments in funds are available at www.bis.org/publ/bcbs266.pdf; and\nfor capital requirements for bank exposures to central counterparties are set out in Section XI of the counterparty credit risk\nstandards.\nBasel III: Finalising post-crisis reforms 3\n\nA. Individual exposures\nDue diligence requirements"}, {"chunk_id": "cbb1d8ea33595d81::485::a2a2", "source_doc": "bcbs189.pdf", "page": 5, "passage": "Several of the capital requirements introduced by the Committee to mitigate the\nrisks arising from firm-level exposures among global financial institutions will also help to\naddress systemic risk and interconnectedness. These include:\nBasel III: A global regulatory framework for more resilient banks and banking systems 7  capital incentives for banks to use central counterparties for over-the-counter\nderivatives;\n higher capital requirements for trading and derivative activities, as well as complex\nsecuritisations and off-balance sheet exposures (eg structured investment vehicles);\n higher capital requirements for inter-financial sector exposures; and\n the introduction of liquidity requirements that penalise excessive reliance on short\nterm, interbank funding to support longer dated assets. B. Introducing a global liquidity standard\n34. Strong capital requirements are a necessary condition for banking sector stability\nbut by themselves are not sufficient. A strong liquidity base reinforced through robust\nsupervisory standards is of equal importance. To date, however, there have been no\ninternationally harmonised standards in this area."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::5c7::68f5", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 10, "passage": "You should obtain the sum of the absolute values of\nexempt supplies from each category to report in your GST return. Category of exempt supplies Exchange gain (loss) for digital\nfor the accounting period from payment tokens\nJan 2020 to Mar 2020\nExchange gain (loss) for digital (200)\npayment tokens Exchange gain (loss) for foreign 400\ncurrency\nInterest received from deposit with 300\nbanks\nValue of exempt supplies |(200)| + 400 + 300\n= $900\nQ9 Can I report the value of supply of digital payment tokens issued during\nmy ICO based on the proceeds received, and then report the value of\nsupply for subsequent transactions based on realised gain or loss? A9 Yes, you may report the proceeds received as the value of supply for ICO\ntransactions. For subsequent exchanges of the tokens for fiat currency or\nother digital payment tokens, you may choose to report the realised gain or\nloss. This is allowed as long as you apply the method chosen consistently.\n14 Contact information\n10.1 For enquiries on this e-Tax Guide, please contact the Goods and Services\nTax Division at www.iras.gov.sg (select \"Contact Us\")\n15 Updates and Amendments\nDate of\nAmendments made\namendment\n1 3 Aug 2022 • Editorial changes.\n• Amended paragraphs 3.6 and 3.8 to reflect the\ndefinition in Income Tax e-Tax Guide on digital\npayment tokens.\n• Added paragraph 5.11 to clarify that if a digital\npayment token is listed on an exchange, IRAS will\nregard the token as suitable for use as a medium\nof exchange."}, {"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}], "rationale": "The Basel Crypto regime (Regime A) regulates capital requirements, risk weighting, and prudential standards for banks and financial institutions. The Singapore IRAS Tax regime (Regime B) regulates tax obligations, specifically regarding the Goods and Services Tax (GST) treatment of digital payment tokens and record-keeping. The obligations in Regime A relate to financial stability and capital adequacy, while the obligations in Regime B relate to tax compliance and GST treatment. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B. The passages confirm that the regimes regulate different domains (financial regulation vs. tax administration)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.78, "record_type": "non_conflict", "pair_id": "non_conflict:ed9fd086dd7aa8a615f07b13", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}], "rationale": "AU_ATO_CRYPTO (Australian token-mapping consultation and crypto tax framework) and EU_DAC8 (EU directive on administrative cooperation for crypto-asset reporting, implementing OECD CARF). Both jurisdictions are implementing internationally-coordinated tax treatments of crypto-assets; DAC8 specifically references the OECD framework which Australia is also working toward. Aligned direction."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:05:58Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:8004c7d3218cabef0ada0508", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "evidence_b": [{"chunk_id": "14cb9eb911d15322::42b::fe23", "source_doc": "2023_Response_PS_Regulations_Amendments.pdf", "page": 22, "passage": "LTD Question 1. MAS seeks comments on the proposed amendments to the Payment Services\nRegulations.\n1. The term safeguarding institution needs to be defined for the purposes of\nRegulation16C. Since DPTSP can self custodize it would be good to have a clear\ndefinition of safeguarding customer's assets. The term \"safeguarding\" is also not\nused/defined in Securities and Futures Act or in the Securities and Futures\n(licensing and conduct of business) regulations in the context of customer\nassets.\n2. It is not clear in these amendments whether a PSA license is a blanket license\nthat will allow the licensee to conduct all of the digital payment token services\n(i.e. broking dealing in DPT, DPT Exchange, DPT Custody) under one PSA license 2 April 2024 | 26\nor would a licensee be granted a PSA license for specific digital payment token\nservices? Trying to draw an analogy here from the Capital Market Services\nLicense (CMSL) where each CMSL holder is given a license outlining the activities\nthat they can do under the CMSL license.\n8 Interactive Brokers Question 1."}], "rationale": "The Basel III framework passage (Regime A) discusses the treatment of fiduciary assets and general provisions for leverage ratio calculations. The Singapore Payment Services Act passage (Regime B) discusses the definition of 'safeguarding institution' and the licensing of Digital Payment Token Services (DPT). The obligations in Regime A relate to banking capital adequacy and accounting treatment, while the obligations in Regime B relate to consumer asset protection and licensing for digital payment services. The regimes regulate distinct domains (banking capital vs. payment services licensing) and do not impose conflicting obligations on the same subject matter."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:4ffc9ad6741cbf83698a1870", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU AML/CTF (AUSTRAC guidance)"}, "regime_b": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU Treasury DAP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}], "evidence_b": [{"chunk_id": "550958b067dc6726::51b::b09b", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 6, "passage": "5 KordaMentha, 'Token mapping: Response to Treasury consultation paper', March 2023. Introduction | 3 laws, digital asset platforms that do not deal in financial products are not subject to financial services\nlaws. The Government intends to introduce a regulatory framework aimed at addressing the significant risks\nand potential harms associated with digital asset platforms, while fostering innovation and safe usage\nof digital assets and distributed ledger technology. The framework outlined in this paper proposes to\nregulate digital asset platforms within the existing Australian financial services laws, while ensuring all\nconsumers and businesses have the opportunity to safely explore and share in any benefits of the\ntechnology. Key terms and concepts used throughout this paper\nUnderstanding the policy problem and the proposed regulatory solution requires an understanding of\nseveral key concepts and terms that are used throughout this paper. These concepts and terms aim to\nreduce the complexity of the paper's content, which necessarily covers topics across industries,\ntechnologies, and regulatory frameworks. They include some broad generalisations for descriptive\nconvenience and some precise technical descriptions for topics stakeholders have identified as causing\nregulatory uncertainty."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): AUSTRAC AML/CTF operational guidance and AU Treasury Digital Asset Platforms framework operate in disjoint regulatory domains at the obligation level. AML/CFT obligations vs Treasury's proposed Digital Asset Platforms framework — different statutory frames and different regulatory purposes. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:016cfb19cc51499adebdbe6e", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3c8::f259", "source_doc": "d424.pdf", "page": 39, "passage": "67 See Annex 10 of Basel II (June 2006) for an overview of methodologies for the capital treatment of transactions secured by\nfinancial collateral under the standardised and IRB approaches.\n\n68 Alternatively, banks with appropriate supervisory approval may instead use the Internal Model Method to determine the\nexposure amount, taking into account collateral.\nBasel III: Finalising post-crisis reforms 35\n\n(ii) On-balance sheet netting\n\n135. Where banks have legally enforceable netting arrangements for loans and deposits that meet the\nconditions in paragraph 190 they may calculate capital requirements on the basis of net credit exposures\nas set out in that paragraph.\n(iii) Guarantees and credit derivatives\n\n136. Where guarantees or credit derivatives fulfil the minimum operational conditions set out in\nparagraphs 191 to 193, banks may take account of the credit protection offered by such credit risk\nmitigation techniques in calculating capital requirements."}, {"chunk_id": "32afd37cade34f84::168::f255", "source_doc": "d424.pdf", "page": 7, "passage": "4 Standards on capital requirements for banks' equity investments in funds are available at www.bis.org/publ/bcbs266.pdf; and\nfor capital requirements for bank exposures to central counterparties are set out in Section XI of the counterparty credit risk\nstandards.\nBasel III: Finalising post-crisis reforms 3\n\nA. Individual exposures\nDue diligence requirements"}, {"chunk_id": "cbb1d8ea33595d81::485::a2a2", "source_doc": "bcbs189.pdf", "page": 5, "passage": "Several of the capital requirements introduced by the Committee to mitigate the\nrisks arising from firm-level exposures among global financial institutions will also help to\naddress systemic risk and interconnectedness. These include:\nBasel III: A global regulatory framework for more resilient banks and banking systems 7  capital incentives for banks to use central counterparties for over-the-counter\nderivatives;\n higher capital requirements for trading and derivative activities, as well as complex\nsecuritisations and off-balance sheet exposures (eg structured investment vehicles);\n higher capital requirements for inter-financial sector exposures; and\n the introduction of liquidity requirements that penalise excessive reliance on short\nterm, interbank funding to support longer dated assets. B. Introducing a global liquidity standard\n34. Strong capital requirements are a necessary condition for banking sector stability\nbut by themselves are not sufficient. A strong liquidity base reinforced through robust\nsupervisory standards is of equal importance. To date, however, there have been no\ninternationally harmonised standards in this area."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::34e::4d5c", "source_doc": "d424.pdf", "page": 84, "passage": "141. Section G discusses the method by which the difference between provisions (eg specific\nprovisions, portfolio-specific general provisions such as country risk provisions or general provisions) and\nexpected losses may be included in or must be deducted from regulatory capital, as outlined in the\ndefinition of capital section of the Basel III framework (June 2011).\n\n1. Calculation of expected losses\n\n142. A bank must sum the EL amount (defined as EL multiplied by EAD) associated with its exposures\nto which the IRB approach is applied (excluding the EL amount associated with securitisation exposures)\nto obtain a total EL amount. The treatment of EL for securitisation exposures is described in paragraph 37\nof the securitisation framework.\n(i) Expected loss for exposures other than exposures subject to the supervisory slotting\ncriteria"}, {"chunk_id": "32afd37cade34f84::25d::6825", "source_doc": "d424.pdf", "page": 85, "passage": "150. At national supervisory discretion, banks using both the standardised and IRB approaches may\nrely on their internal methods for allocating general provisions for recognition in capital under either the\nstandardised or IRB approach, subject to the following conditions. Where the internal allocation method\nBasel III: Finalising post-crisis reforms 81\n\nis made available, the national supervisor will establish the standards surrounding their use. Banks will\nneed to obtain prior approval from their supervisors to use an internal allocation method for this purpose.\n\n3. Treatment of EL and provisions"}, {"chunk_id": "4b8050428e00a093::253::d1c3", "source_doc": "d457.pdf", "page": 113, "passage": "40.32 The derivatives should be converted into positions in the relevant underlying and become subject\nto specific and general market risk charges as described above. In order to calculate the standard\nformula described above, the amounts reported should be the market value of the principal\namount of the underlying or of the notional underlying resulting from the prudent valuation\nguidance set out in paragraphs 690 to 701 in Basel II.[8]\nFootnote\n[8] For instruments where the apparent notional amount differs from the effective notional\namount, banks must use the effective notional amount."}], "rationale": "INT_BASEL_CRYPTO (Basel d424 crypto-asset prudential treatment) and INT_BASEL_GENERAL (Basel III general framework). The crypto-asset standard is part of the broader Basel III framework; both are Basel Committee outputs operating together. Aligned by design."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:bcf8e1c7074daec279d70b15", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "AU_TREASURY_DAP (Australia's proposed Digital Asset Platforms framework — Treasury consultation, broad regulatory mapping) and SG_STABLECOIN (MAS's Single-Currency Stablecoin framework — Singapore-issued G10 stablecoins). Both regulate crypto/stablecoin activities in their respective jurisdictions but apply different mechanisms (AU asset-licensing framework vs SG SCS-issuer framework). Distinct jurisdictional perimeters."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:39:04Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:a5896e121266e6509c2f3566", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "rationale": "The evidence for AU_AML_CTF outlines specific reporting obligations for suspicious matters, threshold transactions, and international funds transfer instructions (chunk 254ca2d92d196180::2ac::a5fe). The evidence for EU_EMD2 is a recital referencing Directive (EU) 2022/2556 regarding digital operational resilience for the financial sector (chunk 85307f9e2a040982::14a::134d). The obligations in the Australian regime relate to AML/CTF reporting, while the EU regime addresses operational resilience. The passages describe different regulatory domains and do not impose conflicting requirements on the same subject matter."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:eeeef198c870efa63c67ce5d", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU AML/CTF Act + Rules"}, "regime_b": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU Treasury DAP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "254ca2d92d196180::369::b111", "source_doc": "Anti-Money Laundering act 2006.pdf", "page": 98, "passage": "Part 2 Identification procedures etc. Division 2 Identification procedures for certain pre-commencement customers\nSection 29\n(b) after the commencement of this section, a suspicious matter\nreporting obligation arises for the reporting entity in relation\nto the customer. Note 1: For suspicious matter reporting obligation, see section 41. Note 2: For tipping-off offences, see section 123. Requirement\n(2) The reporting entity must:\n(a) take such action as is specified in the AML/CTF Rules; and\n(b) do so within the time limit allowed under the AML/CTF\nRules. Civil penalty\n(3) Subsection (2) is a civil penalty provision. Interpretation\n(4) For the purposes of this section, assume that Part 1 had been in\nforce at all material times before the commencement of this\nsection.\n80 Anti-Money Laundering and Counter-Terrorism Financing Act 2006 Identification procedures etc."}], "evidence_b": [{"chunk_id": "550958b067dc6726::51b::b09b", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 6, "passage": "5 KordaMentha, 'Token mapping: Response to Treasury consultation paper', March 2023. Introduction | 3 laws, digital asset platforms that do not deal in financial products are not subject to financial services\nlaws. The Government intends to introduce a regulatory framework aimed at addressing the significant risks\nand potential harms associated with digital asset platforms, while fostering innovation and safe usage\nof digital assets and distributed ledger technology. The framework outlined in this paper proposes to\nregulate digital asset platforms within the existing Australian financial services laws, while ensuring all\nconsumers and businesses have the opportunity to safely explore and share in any benefits of the\ntechnology. Key terms and concepts used throughout this paper\nUnderstanding the policy problem and the proposed regulatory solution requires an understanding of\nseveral key concepts and terms that are used throughout this paper. These concepts and terms aim to\nreduce the complexity of the paper's content, which necessarily covers topics across industries,\ntechnologies, and regulatory frameworks. They include some broad generalisations for descriptive\nconvenience and some precise technical descriptions for topics stakeholders have identified as causing\nregulatory uncertainty."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): Australian AML/CTF Act + Rules (binding instruments) and AU Treasury Digital Asset Platforms framework operate in disjoint regulatory domains at the obligation level. AML/CTF Act and Rules vs proposed DAP framework — disjoint subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:43:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:7028ea4eb3a16da937370015", "label": "non_conflict", "regime_a": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}, {"chunk_id": "6d8a84a9f3d6e9e4::480::ac46", "source_doc": "Guidelines_to_MAS_Notice_SFA04-N02_2025.pdf", "page": 5, "passage": "2 The FSM Sanctions Regulations include the regulations issued under section 192 read with sections 15(1)(b) and 219(d)\nof the FSM Act. Please refer to the following link for the FSM Sanctions Regulations:\nhttps://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions/regulations-for-targeted-financial-\nsanctions. Currently, the relevant FSM Sanctions Regulations are those relating to the Democratic People's Republic of\nKorea and Iran. concerns. Other support functions such as operations, human resource or\ntechnology also play a role to help mitigate the ML/TF risks that the CMI faces. The AML/CFT compliance function is typically the contact point regarding all\nAML/CFT issues for domestic and foreign authorities, including supervisory\nauthorities, law enforcement authorities and financial intelligence units.\n1-4-14 As the third line of defence, the CMI's internal audit function or an equivalent\nfunction plays an important role in independently evaluating the AML/CFT risk\nmanagement framework and controls for purposes of reporting to the audit\ncommittee of the CMI's board of directors, or a similar oversight body."}], "evidence_b": [{"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}, {"chunk_id": "14cb9eb911d15322::42b::fe23", "source_doc": "2023_Response_PS_Regulations_Amendments.pdf", "page": 22, "passage": "LTD Question 1. MAS seeks comments on the proposed amendments to the Payment Services\nRegulations.\n1. The term safeguarding institution needs to be defined for the purposes of\nRegulation16C. Since DPTSP can self custodize it would be good to have a clear\ndefinition of safeguarding customer's assets. The term \"safeguarding\" is also not\nused/defined in Securities and Futures Act or in the Securities and Futures\n(licensing and conduct of business) regulations in the context of customer\nassets.\n2. It is not clear in these amendments whether a PSA license is a blanket license\nthat will allow the licensee to conduct all of the digital payment token services\n(i.e. broking dealing in DPT, DPT Exchange, DPT Custody) under one PSA license 2 April 2024 | 26\nor would a licensee be granted a PSA license for specific digital payment token\nservices? Trying to draw an analogy here from the Capital Market Services\nLicense (CMSL) where each CMSL holder is given a license outlining the activities\nthat they can do under the CMSL license.\n8 Interactive Brokers Question 1."}], "rationale": "The regimes regulate distinct aspects of the digital asset ecosystem. Regime A (MAS AML/CFT) focuses on compliance obligations, specifically the supervision of Digital Payment Token (DPT) providers and the application of AML/CFT regulations (e.g., FSM Sanctions Regulations, internal audit functions) to mitigate money laundering risks. Regime B (PSA) focuses on licensing and operational scope, specifically the definition of 'safeguarding' for customer assets and the structure of a Payment Services (PSA) license relative to Capital Market Services License (CMSL) activities. While both regimes apply to entities providing DPT services, the obligations are complementary rather than conflicting; one governs the anti-money laundering compliance framework, while the other governs the licensing and custody of assets. The shared passage (321e082bdbe732d3::309::b080) confirms that entities may operate under transitional exemptions or license applications, but does not indicate a direct clash between the AML/CFT compliance requirements and the PSA licensing requirements."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:e7fa038a1e47caf882876716", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}], "rationale": "AU_FEDREG_AML (Australian AML/CTF Act and Rules) and INT_FATF_VASP (FATF VASP guidance — AML/CFT standards for VAs and VASPs). Australia's AML/CTF regime applies FATF-aligned obligations on digital-currency-exchange providers (DCE = VASP equivalent). Reinforcing."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:50:12Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:7f57cfa41b789c1ebb3f3a41", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLD6"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}, {"chunk_id": "3a1785f95cb37b3c::34d::1756", "source_doc": "AMLA_Regulation_EU_2024-1620.pdf", "page": 76, "passage": "Article 81\nFinancial rules\nThe financial rules applicable to the Authority shall be adopted by the Executive Board after consulting the Commission.\nThey shall not depart from Delegated Regulation (EU) 2019/715 unless such a departure is specifically required for the\nAuthority's operation and the Commission has given its prior consent.\n(41) Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council of 18 July 2018 on the financial rules\napplicable to the general budget of the Union, amending Regulations (EU) No 1296/2013, (EU) No 1301/2013, (EU) No 1303/2013,\n(EU) No 1304/2013, (EU) No 1309/2013, (EU) No 1316/2013, (EU) No 223/2014, (EU) No 283/2014, and Decision\nNo 541/2014/EU and repealing Regulation (EU, Euratom) No 966/2012 (OJ L 193, 30.7.2018, p. 1).\n76/90 ELI: http://data.europa.eu/eli/reg/2024/1620/oj\n\nEN"}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The EU AMLD6 passages discuss financial rules and operational resilience for the European financial sector (Recital 27 and Article 81), while the SG Foundational Legislation passages focus on MAS enforcement actions against ICO issuers and exchanges, and the intention to align with international AML/CFT standards. The obligations in the EU regime do not impose specific requirements on Singaporean entities or assets that contradict the Singaporean regulatory framework; rather, the SG passages explicitly state an intention to align with international AML/CFT requirements, which includes standards like those referenced in the EU regime. Therefore, the regimes regulate different aspects of the financial system and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:6ddd321d2f4a94b86044bd83", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + TFR"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EMD2"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}], "evidence_b": [{"chunk_id": "6bbad50f6b09cc9d::27e::94d4", "source_doc": "EMD2_Directive_EU_2009-110.pdf", "page": 6, "passage": "Article 4\ntution to hold an amount of own funds which is up to 20 %\nInitial capital higher than the amount which would result from the appli\ncation of the relevant method in accordance with paragraph\nMember States shall require electronic money institutions to\n2, or permit the electronic money institution to hold an\nhold, at the time of authorisation, initial capital, comprised of\namount of own funds which is up to 20 % lower than the\nthe items set out in Article 57(a) and (b) of Directive\namount which would result from the application of the\n2006/48/EC, of not less than EUR 350 000.\nrelevant method in accordance with paragraph 2."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLR/TFR AML/CFT + travel-rule and EU EMD2 e-money-institution directive are designed to coexist — obligations apply cumulatively without collision. EMIs authorised under EMD2 are AMLR-obliged entities; the AML overlay applies cumulatively with EMD2 authorisation. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:59:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:8b6656d9be9c687a3ff9a30f", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::41f::546c", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 24, "passage": "3.1 Standard AFSL Obligations\nAustralian financial services licence\n(a) A platform provider must hold an AFSL authorising them to issue and deal in digital asset facilities.\n(b) A platform provider is exempt from holding an AFSL for digital asset facilities if:\n(i) the total value of platform entitlements held by any one client of the platform provider does\nnot exceed $1,500 at any one time; and\n(ii) the total amount of assets held by the platform provider does not exceed $5 million at any\ntime.\nInfo Box 3 Low value exemption\nThe risks with digital asset facilities are correlated to the size and scale of the asset holding role of\nthe platform provider. Accordingly, a 'low-value facility' exemption would be introduced, similar to\nthe 'low value facility' exemption for non-cash payment facilities. It would apply to digital asset\nfacilities holding less than $1,500 per customer and less than $5 million in total.40 This exemption\nis intended to allow for innovation and experimentation in the early stages of developing a novel\nservice offering."}, {"chunk_id": "550958b067dc6726::709::b159", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 15, "passage": "2.3 Overview of proposed framework\nLicensing\nThe proposed framework would recognise certain asset holding arrangements as a financial product (a\ndigital asset facility). The existing AFSL framework would apply to any person 'carrying on a financial\nservices business in Australia' in relation to a digital asset facility. Examples of 'financial services'\ninclude:\n• dealing in a financial product (including applying for or acquiring, issuing, varying or disposing of a\nfinancial product)\n• making a market for a financial product\n• providing a custodial or depository service, and\n• providing financial product advice.\nThe issuer of a digital asset facility would be the person or persons responsible for the obligations\nowed to customers under the terms of the asset holding arrangement (platform provider). Platform\nproviders and other intermediaries performing financial services in relation to digital asset facilities\n(e.g. brokers, arrangers, agents, market makers, and advisers) would be required to hold an AFSL.\nWhile the application of the AFSL regime would be jurisdictionally limited to Australia in the usual way,\nan intermediary business in Australia, like a broker, would need to be licensed to provide services that\ninvolve dealing in digital asset facilities generally (including those not licensed or located in Australia).\nSee Part 3 for further detail about licensing obligations.\nFacility contracts\nThe proposed framework would permit digital asset facilities to be paired with other functions,\ncreating digital asset platforms. All arrangements involving digital asset facilities would be required to\nbe structured as non-discretionary arrangements.29 The term 'non-discretionary' means the\narrangements must operate according to pre-agreed and transparent rules and procedures."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}, {"chunk_id": "33d059aa86716ddd::4ed::8511", "source_doc": "2022_CP_Stablecoin_Regulatory_Approach.pdf", "page": 6, "passage": "3.5 A wide range of stablecoins currently exist, varying in terms of their asset-\npegging, as well as the mechanism that upholds the stability of the stablecoins' value\nagainst the pegged asset(s). MAS intends to focus its regulatory regime on:\nSingle-currency pegged stablecoins (SCS) - As compared to other types of\nstablecoins (such as those pegged to a basket of currencies or other\nassets such as commodities), SCS has a stronger use case for payment and\nsettlement.\nNon-SCS will continue to be subject to the existing DPT regime under the\nPS Act. MAS views such stablecoins as being less stable in nominal value\nand should be treated differently from SCS.\nIn addition, even among SCS, there is variation in the stabilisation\nmechanism. MAS views stablecoins which are algorithmically-pegged,\nunbacked or backed by other cryptocurrencies to be more susceptible to\nvolatility in value. Correspondingly, such stablecoins will also continue to\nbe treated as DPTs.\nSCS issued in Singapore - The immediate priority of MAS is to elevate the\nstandard of SCS issued in Singapore. Our regulatory perimeter is thus\nscoped based on MAS' ability to directly impose requirements on the\nreserve management, redemption policies and prudential standards of\nthe SCS issuer."}], "rationale": "The Australian regime (AU_ASIC_AFSL) regulates the provision of financial services, specifically the holding of an Australian Financial Services Licence (AFSL) to issue and deal in digital asset facilities. The Singapore regime (SG_STABLECOIN) regulates the issuance of Single-Currency Stablecoins (SCS) under the Payment Services Act. The evidence shows that the Singapore regime focuses on the 'perimeter' of SCS issuance and reserve management (chunk_id 33d059aa86716ddd::4ed::8511), while the Australian regime focuses on the licensing of intermediaries providing financial services (chunk_id 550958b067dc6726::709::b159). There is no evidence in the provided passages of a specific obligation in one regime that directly conflicts with a specific obligation in the other. The regimes regulate different aspects of the digital asset ecosystem: one on the licensing of the service provider, and the other on the classification and reserve requirements of the specific token product."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:36:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:8425a87ead5b3c264376b5aa", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The EU_PSD2 passages regulate the authentication of payment transactions and the authorisation of payment service providers (chunk_ids adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b). The INT_BASEL_CRYPTO passages regulate the calculation of capital requirements and the risk weighting of bank exposures to financial institutions (chunk_ids 32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). The obligations in PSD2 regarding strong customer authentication and governance do not impose specific constraints on the capital treatment or risk weighting of exposures defined in the Basel framework. Therefore, the regimes regulate distinct domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:8dbd5e00779b4f3142ff2c88", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "75b61beed88910f9::4ad::debc", "source_doc": "National_ML_TF_Risk_Assessment.pdf.coredownload.inline.pdf", "page": null, "passage": "The guidance contained in this document takes into consideration previous FATF work , which is still valid reference material. The general\nprinciples contained in this paper are also relevant when conducting risk assessments of a more\nfocussed scope, such as in assessments of a particular financial or DNFBP sector (for example, the\nsecurities sector) or of thematic issues (for example, the proceeds of corruption related ML). All of\nthese types of assessments (comprehensive, sectoral or thematic) carried out at the national level\nmay also form the basis for determining whether to apply enhanced or specific measures, simplified\nmeasures, or exemptions from AML/CFT requirements. Furthermore, while FATF\nRecommendation 1 does not create specific risk assessment obligations regarding the financing of\nproliferation of weapons of mass destruction, the general principles laid out in this guidance could\nalso be used in conducting a risk assessment for this area.\n3. The guidance in this document is not intended to explain how supervisors should assess risks\nin the context of risk-based supervision, although risk-based supervision will likely be informed by a\nnational-level risk assessment."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::284::b4a8", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 38, "passage": "94. The FATF Standards, including the definitions of virtual assets and VASPs, represent\na minimum standard for countries to introduce. In line with the RBA, countries may\nchoose to extend their AML/CFT regimes to include other digital assets and entities,\nbeyond the FATF definition of virtual asset and VASP. Such a determination should\nbe made on the basis of a ML/TF risk assessment, with consideration of the\nchallenges associated with regulatory divergence.\n\nUPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS  37\nPART THREE:\nAPPLICATION OF FATF STANDARDS TO COUNTRIES AND\nCOMPETENT AUTHORITIES"}], "rationale": "INT_FATF_GENERAL (FATF general AML/CFT standards) and INT_FATF_VASP (FATF VASP-specific guidance). Both are parts of the same FATF Recommendations framework; the VASP guidance extends FATF standards to virtual assets. Aligned by design."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:55:51Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:caf0ce3d0a3fc19cb7b42062", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "evidence_b": [{"chunk_id": "20d526d712753652::1a4::2e6e", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Notabene commend's the Monetary Authority of Singapore (MAS) for proposing a\ncomprehensive and detailed regulatory approach for Digital Token Service Providers\n(DTSPs) under the Financial Services and Markets Act 2022. Our comments focus on\nthe alignment of these notices and guidelines with international standards,\nparticularly in light of Financial Action Task Force (FATF) Recommendations,\nincluding the Travel Rule."}, {"chunk_id": "20d526d712753652::4b9::b812", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": 71, "passage": "(Please refer to paragraph 12 of the draft FSM Notice). The proposed requirements for Correspondent Account Services (CAS) in paragraph\n5.6 of the draft FSM Notice are both applicable and appropriate for the digital token\nservice provider (DTSP) sector. Given the inherent cross-border nature and rapid\ntransactions within digital token services, the FATF-aligned risk mitigation measures\nensure that DTSPs are aligned with global AML/CFT standards, providing a secure\nframework for correspondent services while addressing potential ML/TF risks. Applicability of Risk Mitigation Measures\nThe requirement for DTSPs to assess the suitability of financial institutions when\nproviding or receiving CAS, including evaluating their AML/CFT controls, is essential\nfor preventing potential misuse of these services. The dynamic and often cross-\njurisdictional interactions in digital token services make these standards particularly\nrelevant to ensuring consistent risk management. MAS could consider offering\nguidance on specific factors DTSPs should evaluate, such as transaction monitoring\ncapabilities and the jurisdiction's regulatory reputation, to better equip licensees in\napplying a comprehensive assessment."}], "rationale": "The FATF Guidance on Digital Identity (Regime A) focuses on customer identification and due diligence in the digital context. The Singapore DTSP consultation (Regime B) addresses the licensing and operational requirements for Digital Token Service Providers, including the alignment of its rules with international standards like the FATF Travel Rule. While both regimes reference FATF standards, the specific obligations in Regime A (digital identity verification) are not in conflict with the specific obligations in Regime B (licensing and correspondent account services). In fact, Regime B explicitly acknowledges the alignment of its approach with FATF Recommendations, including the Travel Rule, and notes that FATF-aligned risk mitigation measures are appropriate for the sector. Therefore, the regimes are aligned and complementary rather than conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:23:18Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:384b79accaffbe267cde4136", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DORA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::5f2::974e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 23, "passage": "Article 1\nSubject matter\n1. In order to achieve a high common level of digital operational resilience, this Regulation lays down uniform\nrequirements concerning the security of network and information systems supporting the business processes of financial\nentities as follows:\n(a) requirements applicable to financial entities in relation to:\n(i) information and communication technology (ICT) risk management;\n(ii) reporting of major ICT-related incidents and notifying, on a voluntary basis, significant cyber threats to the\ncompetent authorities;\n(iii) reporting of major operational or security payment-related incidents to the competent authorities by financial\nentities referred to in Article 2(1), points (a) to (d);\n(iv) digital operational resilience testing;\n(v) information and intelligence sharing in relation to cyber threats and vulnerabilities;\n(vi) measures for the sound management of ICT third-party risk;\n(b) requirements in relation to the contractual arrangements concluded between ICT third-party service providers and\nfinancial entities;\n(c) rules for the establishment and conduct of the Oversight Framework for critical ICT third-party service providers when\nproviding services to financial entities;\n(d) rules on cooperation among competent authorities, and rules on supervision and enforcement by competent\nauthorities in relation to all matters covered by this Regulation.\n2. In relation to financial entities identified as essential or important entities pursuant to national rules transposing"}], "rationale": "The AU_FEDREG_AML regime focuses on Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations, specifically customer identification, transaction reporting, and suspicious activity reporting for reporting entities (chunk cf7cefacba3f94bc::49a::f39e). The EU_DORA regime focuses on Digital Operational Resilience and ICT risk management for financial entities (chunk 85307f9e2a040982::5f2::974e). The obligations in the AML regime (reporting suspicious transactions) are complementary to the resilience obligations in DORA (reporting major ICT-related incidents) rather than conflicting. There is no evidence in the provided passages of a specific obligation in AML that pushes against a specific obligation in DORA."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:08:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:473a0582177cc27b626588e8", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d7502c011527b67c::3e7::ae26", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 13, "passage": "This Regulation shall not apply to a transfer of funds where any of the following conditions is met:\n(a) it involves the payer withdrawing cash from the payer's own payment account;\n(b) it constitutes a transfer of funds to a public authority as payment for taxes, fines or other levies within a Member\nState;\n(c) both the payer and the payee are payment service providers acting on their own behalf;\n(d) it is carried out through cheque images exchanges, including truncated cheques. This Regulation shall not apply to a transfer of crypto-assets where any of the following conditions is met:\n(a) both the originator and the beneficiary are crypto-asset service providers acting on their own behalf;\n(b) the transfer constitutes a person-to-person transfer of crypto-assets carried out without the involvement of a crypto-\nasset service provider. Electronic money tokens, as defined in Article 3(1), point (7), of Regulation (EU) 2023/1114, shall be treated as crypto-\nassets under this Regulation."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "The EU regime regulates the information accompanying transfers of funds and crypto-assets to ensure traceability for AML/CFT purposes (chunk_id=d7502c011527b67c::3e7::ae26). The Singapore regime regulates the issuance and reserve requirements of Single Currency Stablecoins (SCS) under the Payment Services Act (chunk_id=58f45cd2ef3de201::36c::e2f6). The obligations are distinct: one focuses on the transfer and accompanying information of crypto-assets, while the other focuses on the issuance standards and reserve management of specific stablecoin products. There is no specific obligation in the EU regime that pushes against a specific obligation in the Singapore regime; rather, they regulate different aspects of the digital asset ecosystem."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:39:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:beee9a65e821983d96ebace8", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "rationale": "The evidence from the Australian regime (Regime A) focuses on the licensing and classification of crypto-assets as financial products under the Corporations Act (e.g., INFO 225, AFS licences) and explicitly notes that it does not cover obligations administered by other regulators like AUSTRAC or the ATO. The evidence from the EU regime (Regime B) concerns the scope of Anti-Money Laundering (AML) obligations for crypto-asset service providers. While both regimes regulate crypto-assets, they address distinct regulatory domains: one focuses on financial product licensing and consumer protection, while the other focuses on AML/CFT compliance. The passages do not indicate a specific obligation in one regime that conflicts with a specific obligation in the other; rather, they describe separate regulatory frameworks."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:310097910840d396fdfeaa2a", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}, {"chunk_id": "c51ad46265cea4e5::462::80d8", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 76, "passage": "6.5 Annex V - Draft RTS pursuant to Article 62(5) of MiCA\nCOMMISSION DELEGATED REGULATION (EU) .../...\nof XXX\nsupplementing Regulation (EU) 2023/1114 of the European Parliament and of the\nCouncil with regard to regulatory technical standards specifying the information to be\nincluded in an application for authorisation as crypto-asset service provider\n(Text with EEA relevance)\nTHE EUROPEAN COMMISSION,\nHaving regard to the Treaty on the Functioning of the European Union,\nHaving regard to Regulation (EU) 2023/1114 of the European Parliament and of the Council\nof 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2012\nand (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/193718, and in particular\nArticle 62(5), third subparagraph, thereof,\nWhereas:\n(1) The information to be provided in an application for authorisation as crypto-asset service\nprovider should be sufficiently detailed and comprehensive to enable competent\nauthorities to assess whether an applicant meets the applicable requirements laid down\nin Title V and, where relevant, Title VI of Regulation (EU) 2023/1114."}], "rationale": "AU_ASIC_CRYPTO (ASIC's interpretation of when crypto-assets are financial products under the Corporations Act, with AFSL licensing implications) and EU_MICA (EU framework for crypto-asset services and CASP authorisation). Both regulate crypto-asset service providers and their products but apply in non-overlapping jurisdictions with materially different perimeters — AU classifies by financial-product status; EU MiCA establishes a dedicated CASP regime. The cited passages don't impose conflicting obligations on the same entity action; an entity operating in both must comply with each separately."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:f2a45336ca62f150eebd887e", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "9a96d4d1812f257a::2a6::2422", "source_doc": "161011-APRA-RIS-margining-risk-mitigation-final-assessment-second-pass.pdf", "page": 2, "passage": "2 APRA's prudential framework comprises prudential standards and prudential practice guides (PPGs). APRA is\nempowered to issue legally binding prudential standards that set out specific requirements with which APRA-regulated\ninstitutions - authorised deposit-taking institutions (ADIs), general insurers and life companies (collectively,\ninsurers) and registrable superannuation entity licensees (RSE licensees) - must comply. APRA also issues PPGs,\nwhich clarify APRA's expectations with regard to prudential matters. PPGs frequently discuss legal requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements."}], "rationale": "AU_APRA_CPS230 (APRA Operational Risk Management prudential standard) and AU_APRA_PRUDENTIAL (APRA's broader prudential framework — prudential standards and PPGs). CPS 230 is part of APRA's broader prudential framework; they operate together as part of the same coordinated AU prudential architecture."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:b96bd74de6fb53452cd95e3c", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU Privacy"}, "regime_b": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}, {"chunk_id": "6c3ed2e60520c185::546::b286", "source_doc": "Privacy_Act_1988.pdf", "page": 376, "passage": "Part 1-Consideration of personal information\nprivacy\n1 Australian Privacy Principle 1-open and transparent\nmanagement of personal information\n1.1 The object of this principle is to ensure that APP entities manage\npersonal information in an open and transparent way. Compliance with the Australian Privacy Principles etc.\n1.2 An APP entity must take such steps as are reasonable in the\ncircumstances to implement practices, procedures and systems\nrelating to the entity's functions or activities that:\n(a) will ensure that the entity complies with the Australian\nPrivacy Principles and a registered APP code (if any) that\nbinds the entity; and\n(b) will enable the entity to deal with inquiries or complaints\nfrom individuals about the entity's compliance with the\nAustralian Privacy Principles or such a code. APP Privacy policy\n1.3 An APP entity must have a clearly expressed and up-to-date policy\n(the APP privacy policy) about the management of personal\ninformation by the entity.\n1.4 Without limiting subclause 1.3, the APP privacy policy of the APP\nentity must contain the following information:\n(a) the kinds of personal information that the entity collects and\nholds;\n(b) how the entity collects and holds personal information;\n(c) the purposes for which the entity collects, holds, uses and\ndiscloses personal information;\n358 Privacy Act 1988"}], "evidence_b": [{"chunk_id": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}, {"chunk_id": "85307f9e2a040982::36a::b013", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 38, "passage": "27.12.2022 EN Official Journal of the European Union L 333/39\n(h) implement, as appropriate, relevant operational conclusions resulting from the tests referred to in point (g) and from\npost-incident analysis into the ICT risk assessment process and develop, according to needs and ICT risk profile, ICT\nsecurity awareness programmes and digital operational resilience training for staff and management.\n2. The ICT risk management framework referred to in paragraph 1, second subparagraph, point (a), shall be documented\nand reviewed periodically and upon the occurrence of major ICT-related incidents in compliance with supervisory\ninstructions. It shall be continuously improved on the basis of lessons derived from implementation and monitoring. A\nreport on the review of the ICT risk management framework shall be submitted to the competent authority upon its\nrequest.\n3."}], "rationale": "AU Privacy Act / APPs regulate Australian APP entities' handling of personal information. DORA regulates EU financial entities' ICT risk management. Different jurisdictions, different regulated populations, different subject matters. Textbook easy negative; included for class-balance and to give the trainer a clear different-domain different-jurisdiction example.", "would_conflict_if": ["An Australian-EU dual-regulated firm — the two regimes would apply cumulatively on its respective jurisdictional surface; no obligation collision."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:19:24Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:f8c89692d70d40c0e9cec7d1", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::5c7::68f5", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 10, "passage": "You should obtain the sum of the absolute values of\nexempt supplies from each category to report in your GST return. Category of exempt supplies Exchange gain (loss) for digital\nfor the accounting period from payment tokens\nJan 2020 to Mar 2020\nExchange gain (loss) for digital (200)\npayment tokens Exchange gain (loss) for foreign 400\ncurrency\nInterest received from deposit with 300\nbanks\nValue of exempt supplies |(200)| + 400 + 300\n= $900\nQ9 Can I report the value of supply of digital payment tokens issued during\nmy ICO based on the proceeds received, and then report the value of\nsupply for subsequent transactions based on realised gain or loss? A9 Yes, you may report the proceeds received as the value of supply for ICO\ntransactions. For subsequent exchanges of the tokens for fiat currency or\nother digital payment tokens, you may choose to report the realised gain or\nloss. This is allowed as long as you apply the method chosen consistently.\n14 Contact information\n10.1 For enquiries on this e-Tax Guide, please contact the Goods and Services\nTax Division at www.iras.gov.sg (select \"Contact Us\")\n15 Updates and Amendments\nDate of\nAmendments made\namendment\n1 3 Aug 2022 • Editorial changes.\n• Amended paragraphs 3.6 and 3.8 to reflect the\ndefinition in Income Tax e-Tax Guide on digital\npayment tokens.\n• Added paragraph 5.11 to clarify that if a digital\npayment token is listed on an exchange, IRAS will\nregard the token as suitable for use as a medium\nof exchange."}, {"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}], "rationale": "EU_GDPR (Article 44+ cross-border data transfer restrictions) and SG_IRAS_TAX (IRAS GST and crypto-asset tax framework — recordkeeping and information requests on Singapore taxpayers' transactions including those involving EU counterparties or operators). When SG entities handle EU-resident customer data for IRAS reporting / GST audit purposes, GDPR Chapter V cross-border transfer restrictions engage on the EU side. Operationally resolvable via GDPR Article 6(1)(c) (legal-obligation lawful basis) plus Chapter V mechanisms (SCCs / Art. 49 derogations) or via the EU-SG competent-authority tax-info-exchange agreement framework. Same conflict shape as the labelled DAC8 × PDPA conflict, applied to EU-SG tax-reporting context.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:42Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:31:12Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:fd24403389ed98e33fef67ca", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::41f::546c", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 24, "passage": "3.1 Standard AFSL Obligations\nAustralian financial services licence\n(a) A platform provider must hold an AFSL authorising them to issue and deal in digital asset facilities.\n(b) A platform provider is exempt from holding an AFSL for digital asset facilities if:\n(i) the total value of platform entitlements held by any one client of the platform provider does\nnot exceed $1,500 at any one time; and\n(ii) the total amount of assets held by the platform provider does not exceed $5 million at any\ntime.\nInfo Box 3 Low value exemption\nThe risks with digital asset facilities are correlated to the size and scale of the asset holding role of\nthe platform provider. Accordingly, a 'low-value facility' exemption would be introduced, similar to\nthe 'low value facility' exemption for non-cash payment facilities. It would apply to digital asset\nfacilities holding less than $1,500 per customer and less than $5 million in total.40 This exemption\nis intended to allow for innovation and experimentation in the early stages of developing a novel\nservice offering."}, {"chunk_id": "550958b067dc6726::74a::7ef1", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 26, "passage": "46 For information on ASIC's interpretation of this obligation, see ASIC PF 209 Australian financial services\nlicence conditions\nLicensing digital asset intermediaries | 23\n\n(vi) having the financial,47 technological, and human resources to carry out and supervise the\nfinancial service covered by the AFSL,\n(vii) having a dispute resolution system48 and compensation arrangements for retail clients for\nloss or damage suffered due to breaches of obligations, and\n(viii) maintaining a risk management system.\nFinancial requirements\n(g) A platform provider must meet:\n(i) the standard solvency and positive net asset requirements,49\n(ii) the standard cash needs requirement, and\n(iii) a net tangible assets (NTA) requirement for holding cash or cash equivalents and holding\nliquid assets of at least:\n• 0.5 per cent of the value of the facility (if using a sub-custodian digital asset facility that\nhas $5m NTA),50 or\n• $5 million (if performing the custody function).\nInfo Box 6 Financial requirements\nAFSL holders have obligations to meet 'financial requirements'. These requirements are typically\ntailored for different financial products through ASIC legislative instruments. The NTA obligation is\nto address the costs of orderly wind-up in the event the provider fails.51\nA key issue with digital assets is concentration risk (see Info Box 11 Additional Standards for token\nholders). The proposed financial requirements balance the need to avoid concentration of digital\nassets among a small number of custodians with the need to ensure robust NTA. It sets the\nrequired level of NTA at the greater of $5 million or 0.5% of the value of the assets held by the\nfacility.52 This arrangement ensures that as a facility expands, and the operational risk exposure of\nthe platform provider grows, the provider will maintain a corresponding level of financial\nresources."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The regimes regulate distinct aspects of the financial ecosystem. Regime A (AU_ASIC_AFSL) establishes licensing and conduct obligations for entities providing financial services, specifically digital asset facilities, including financial requirements and AFSL authorisation (chunk_ids 550958b067dc6726::41f::546c, 550958b067dc6726::74a::7ef1). Regime B (INT_BASEL_CRYPTO) focuses on prudential capital requirements for banks, defining exposures and risk weights for financial institutions (chunk_ids 32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other; rather, they apply to different entities (platform providers vs. banks) and different regulatory objectives (licensing/conduct vs. capital adequacy)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:30:48Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:91a03a3a959b30250bdcf52b", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The evidence for Regime A (AU_APRA_CPS230) focuses on operational risk management, business continuity, and the management of service providers to ensure resilience and prudential obligations (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c). The evidence for Regime B (SG_FOUNDATIONAL_LEGISLATION) discusses the regulation of digital tokens, securities, and the Payment Services Act, specifically referencing MAS enforcement actions and the intention to align with international AML/CFT standards (chunk_ids b49627bb889ef1d9::3ef::7168, d6f4be6b9d136778::467::12af). The obligations in Regime A relate to internal risk management and continuity planning, while the obligations in Regime B relate to the licensing and conduct of digital token activities. These are distinct regulatory domains; there is no specific obligation in Regime A that pushes against a specific obligation in Regime B. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:52:33Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:ab6c281db586540724616bab", "label": "non_conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "adb1a81b9cecaf8c::3ac::b555", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 16, "passage": "(89) Provision of payment services by the payment services providers may entail processing of personal data. Directive\n95/46/EC of the European Parliament and of the Council ( 1) , the national rules which transpose Directive 95/46/EC\nand Regulation (EC) No 45/2001 of the European Parliament and of the Council ( 2 ) are applicable to the\nprocessing of personal data for the purposes of this Directive. In particular, where personal data is processed\nfor the purposes of this Directive, the precise purpose should be specified, the relevant legal basis referred to, the\nrelevant security requirements laid down in Directive 95/46/EC complied with, and the principles of necessity,\nproportionality, purpose limitation and proportionate data retention period respected. Also, data protection by\ndesign and data protection by default should be embedded in all data processing systems developed and used\nwithin the framework of this Directive."}, {"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "evidence_b": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}, {"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The EU GDPR passages discuss data protection principles, lawful processing, and international data transfers (e.g., Article 6, Article 44, Recital 89). The MAS TRM passages discuss internal processes for inaccurate representations, the application of guidelines (F&P, TRM, Business Continuity), and principles-based risk assessments. The obligations in the GDPR passages relate to the protection of personal data, whereas the obligations in the MAS TRM passages relate to the conduct of regulated entities and risk management. There is no specific obligation in the GDPR that pushes against a specific obligation in the MAS TRM; rather, they regulate distinct domains of compliance. Therefore, the regimes are in non_conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:24:12Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:e4cbc2d71cd3fb5254803e79", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The evidence from AU_TREASURY_DAP discusses the Australian government's 'token mapping' exercise and the development of a licensing framework for crypto asset service providers (chunk_id d75262e404517e0c::47b::7c9f). The evidence from MAS_TRM discusses the application of the 'TRM Guidelines' (Treasury Management Guidelines) to licensees, describing them as principles-based statements of industry best practices (chunk_id 20d526d712753652::401::f956). The two regimes regulate different domains: one is a national regulatory reform agenda for crypto assets in Australia, while the other is a set of operational guidelines for financial institutions in Singapore. There is no specific obligation in one regime that pushes against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:36:04Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:41418d6d2d673d439da25106", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4024f4c4c1616cc::23d::700a", "source_doc": "AMLR_Regulation_EU_2024-1624.pdf", "page": 2, "passage": "(7) Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers\nof funds and certain crypto-assets and amending Directive (EU) 2015/849 (OJ L 150, 9.6.2023, p. 1).\n\n(8) Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing the Authority for\nAnti-Money Laundering and Countering the Financing of Terrorism and amending Regulations (EU) No 1093/2010, (EU)\nNo 1094/2010 and (EU) No 1095/2010 (OJ L, 2024/1620, 19.6.2024, http://data.europa.eu/eli/reg/2024/1620/oj)."}, {"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The EU regime (Regulation (EU) 2023/1113) establishes obligations for crypto-asset service providers to accompany transfers of funds with information on the payer and payee to ensure traceability for AML/CFT purposes. The Singapore regime (MAS communications and legislative intent) focuses on the authorisation of digital token exchanges and issuers, specifically targeting activities involving securities or futures contracts, and aims to align with international AML/CFT standards. The obligations in the EU regulation relate to the technical traceability of crypto-asset transfers, while the Singapore regime addresses the licensing and conduct of entities offering digital tokens. These are distinct regulatory domains; the EU rules do not impose a specific obligation that conflicts with the Singaporean requirement for authorisation or the MAS's focus on securities tokens. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:1e0310a5537ca7dbcb402ea2", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "PSD2"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::43b::29d2", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 6, "passage": "(30) The personalised security credentials used for secure customer authentication by the payment service user or by the\npayment initiation service provider are usually those issued by the account servicing payment service providers.\nPayment initiation service providers do not necessarily enter into a contractual relationship with the account\nservicing payment service providers and, regardless of the business model used by the payment initiation service\nproviders, the account servicing payment service providers should make it possible for payment initiation service\nproviders to rely on the authentication procedures provided by the account servicing payments service providers to\ninitiate a specific payment on behalf of the payer.\n\n(31) When exclusively providing payment initiation services, the payment initiation service provider does not at any\nstage of the payment chain hold the user's funds. When a payment initiation service provider intends to provide\npayment services in relation to which it holds user funds, it should obtain full authorisation for those services."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLD 6 AML supervisory directive and EU PSD2 payment-services directive are designed to coexist — obligations apply cumulatively without collision. PSPs are AMLR/AMLD6 obliged entities — supervisory regime applies cumulatively with PSD2. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:10:09Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:d5aa8bc012fd487680ea4ef1", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "The FATF passage (chunk 85240528438654b9::396::417b) discusses the FATF's application of standards to 'so-called stablecoins' and the need for guidance. The Singapore passage (chunk 58f45cd2ef3de201::36c::e2f6) outlines the MAS's specific regulatory perimeter for 'Single-currency stablecoins (SCS)' issued in Singapore. The regimes address the same topic (stablecoins) but from different perspectives: FATF provides global AML/CFT standards applicable to VASPs, while MAS defines a domestic regulatory framework for specific stablecoin types. The obligations do not push against one another; rather, FATF standards would inform the AML/CFT obligations within MAS's framework. Therefore, the regimes are non-conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:26:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:a046b520febfb2ca89876599", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}], "rationale": "The Australian AML/CTF regime (Regime A) focuses on anti-money laundering obligations for reporting entities, including customer identification, transaction reporting, and suspicious activity reporting (chunk cf7cefacba3f94bc::49a::f39e). The Singapore Payment Services Act (Regime B) passage (chunk 321e082bdbe732d3::309::b080) discusses the regulatory scope of Digital Payment Token (DPT) services, specifically transitional exemptions and licensing requirements. The passages describe distinct regulatory frameworks for different jurisdictions (Australia vs. Singapore) and different regulatory objectives (AML compliance vs. DPT service licensing). There is no evidence of a specific obligation in Regime A that conflicts with a specific obligation in Regime B. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:36:58Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:95fddd0d4e6e9b8724b39db7", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}], "rationale": "The evidence from Regime A (AU_AML_CTF) outlines general reporting obligations for suspicious matters and threshold transactions under the AML/CTF Act. The evidence from Regime B (EU_MICA_TITLE_V_CASP) focuses on the specific requirements for applying for authorisation as a Crypto-Asset Service Provider (CASP) under MiCA. The obligations in Regime A relate to financial crime reporting, while the obligations in Regime B relate to market entry and licensing for crypto-asset services. The passages describe distinct regulatory domains and do not impose conflicting obligations on the same activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:34:45Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:2eb3c022db64f726ab321aab", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::25d::6825", "source_doc": "d424.pdf", "page": 85, "passage": "150. At national supervisory discretion, banks using both the standardised and IRB approaches may\nrely on their internal methods for allocating general provisions for recognition in capital under either the\nstandardised or IRB approach, subject to the following conditions. Where the internal allocation method\nBasel III: Finalising post-crisis reforms 81\n\nis made available, the national supervisor will establish the standards surrounding their use. Banks will\nneed to obtain prior approval from their supervisors to use an internal allocation method for this purpose.\n\n3. Treatment of EL and provisions"}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}, {"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "The Basel III framework (Regime A) regulates banking capital adequacy, leverage ratios, and credit risk provisions. The Singapore Digital Token Service Provider (DTSP) regime (Regime B) regulates the licensing and conduct of digital token service providers under the Financial Services and Markets Act 2022. The cited passages from Regime A discuss accounting treatment for fiduciary assets and general provisions (chunk_ids 32afd37cade34f84::34b::8d30, 32afd37cade34f84::25d::6825). The cited passages from Regime B discuss the definition of DTSPs, licensing requirements, and the suspension of services outside Singapore (chunk_ids 20d526d712753652::404::80be, cc1be49e9cf8c821::2f4::ea8f). There is no specific obligation in the Basel framework that conflicts with the licensing or operational obligations of DTSPs under the FSM Act. The regimes regulate distinct sectors (banking vs. digital token services) and different aspects of financial stability."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:14:48Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:11fad46a07f3bb85c26be940", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e3809bb1f352508e::38a::ddd7", "source_doc": "Guidelines_Reverse_Solicitation_MiCA.pdf", "page": 14, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}, {"chunk_id": "25cbbd878a1b21d3::38a::ddd7", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 47, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}], "evidence_b": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}, {"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The EU_MICA passages describe obligations for crypto-asset service providers (CASPs) regarding market abuse prevention, knowledge and competence, and the provision of specific crypto-asset services (e.g., advice, asset-referenced tokens). The MAS_TRM passages describe the application of general financial institution guidelines (such as Fit and Proper Criteria and Business Continuity Management) to licensees, and the principles-based nature of the TRM Guidelines. The obligations in EU_MICA are specific to the crypto-asset sector and market integrity, while the obligations in MAS_TRM are general supervisory guidelines applicable to financial institutions. There is no specific obligation in EU_MICA that pushes against a specific obligation in MAS_TRM; rather, they regulate different domains (crypto-asset specific vs. general financial institution supervision)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:56:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:bac20e196e16cc7f297cf174", "label": "non_conflict", "regime_a": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}, {"chunk_id": "cc1be49e9cf8c821::3fc::a271", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "1.1 The Guidelines on Licensing for Digital Token Service Providers (the \"Guidelines\")\nare intended to provide guidance on the application procedures, licensing criteria and\nongoing requirements for Digital Token Service Providers under Part 9 of the Financial\nServices and Markets Act 2022 (the \"FSM Act\"). Under this, digital token service providers are\ndefined as individuals, partnerships or Singapore corporations that are operating from a place\nof business in Singapore or formed or incorporated in Singapore but carry on a business of\nproviding digital token services outside Singapore (\"DTSPs\").\n\n1.2 These Guidelines should be read in conjunction with the provisions of the FSM Act,\nthe Financial Services and Markets (Digital Token Service Provider) Regulations (the \"FSM\nRegulations\") and other relevant legislation, notices, guidelines and FAQs issued by the\nMonetary Authority of Singapore (\"MAS\").\n\n1.3 MAS will update these Guidelines periodically to provide further guidance.\n2. Licence under the FSM Act"}, {"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::5c7::68f5", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 10, "passage": "You should obtain the sum of the absolute values of\nexempt supplies from each category to report in your GST return. Category of exempt supplies Exchange gain (loss) for digital\nfor the accounting period from payment tokens\nJan 2020 to Mar 2020\nExchange gain (loss) for digital (200)\npayment tokens Exchange gain (loss) for foreign 400\ncurrency\nInterest received from deposit with 300\nbanks\nValue of exempt supplies |(200)| + 400 + 300\n= $900\nQ9 Can I report the value of supply of digital payment tokens issued during\nmy ICO based on the proceeds received, and then report the value of\nsupply for subsequent transactions based on realised gain or loss? A9 Yes, you may report the proceeds received as the value of supply for ICO\ntransactions. For subsequent exchanges of the tokens for fiat currency or\nother digital payment tokens, you may choose to report the realised gain or\nloss. This is allowed as long as you apply the method chosen consistently.\n14 Contact information\n10.1 For enquiries on this e-Tax Guide, please contact the Goods and Services\nTax Division at www.iras.gov.sg (select \"Contact Us\")\n15 Updates and Amendments\nDate of\nAmendments made\namendment\n1 3 Aug 2022 • Editorial changes.\n• Amended paragraphs 3.6 and 3.8 to reflect the\ndefinition in Income Tax e-Tax Guide on digital\npayment tokens.\n• Added paragraph 5.11 to clarify that if a digital\npayment token is listed on an exchange, IRAS will\nregard the token as suitable for use as a medium\nof exchange."}, {"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}], "rationale": "The SG_FSMA_DTSP passages regulate the licensing and conduct of Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022, focusing on AML/CFT obligations, licensing criteria, and the suspension of services outside Singapore by 30 June 2025 (chunk_ids 20d526d712753652::404::80be, cc1be49e9cf8c821::3fc::a271, cc1be49e9cf8c821::2f4::ea8f). In contrast, the SG_IRAS_TAX passages address the Goods and Services Tax (GST) treatment of digital payment tokens, specifically noting that their supply is exempt from GST and that businesses trading in them are no longer liable for GST registration (chunk_ids abc2247bc6415d1d::5c7::68f5, abc2247bc6415d1d::41e::b184). The two regimes regulate distinct aspects of the digital token ecosystem—financial services regulation versus tax treatment—resulting in no direct conflict between the obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:56:10Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:2ba556e26369ca6f3f9167b2", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "The EU MiCA RTS passage discusses the notification obligations for financial entities providing crypto-asset services under Article 60(7) and the development of RTS on sustainability indicators and market abuse (chunk_id=c51ad46265cea4e5::2f5::4513). The Singapore Stablecoin passage outlines the regulatory perimeter for Single-Currency Stablecoins (SCS) issued in Singapore, distinguishing them from Non-SCS which remain under the existing DPT regime (chunk_id=58f45cd2ef3de201::36c::e2f6). The obligations in MiCA regarding notification and sustainability reporting apply to crypto-asset service providers and issuers within the EU, while the Singapore regime focuses on the specific issuance and reserve requirements of SCS pegged to SGD or G10 currencies. The regimes regulate different aspects of the crypto-asset ecosystem (general crypto-asset service provision and notification vs. specific stablecoin issuance standards) and do not impose conflicting obligations on the same entity or transaction type."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:02:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:6f6c928e8652310a281f3178", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::2bc::cafa", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 9, "passage": "19. Article 62(4) of MiCA sets out that NCAs must not require an applicant CASP to provide\nany information referred to in Article 62(2) of MiCA that they have already received under\nthe respective authorisation procedures in accordance with Directive 2009/110/EC4,\n2014/65/EU5 or (EU) 2015/23666, or pursuant to national law applicable to crypto-asset\nservices prior to the date of entry into force of MiCA, provided that such previously\nsubmitted information or documents are still up-to-date.\n\n3.2 Feedback statement\nQ2: Do you agree with the list of information to be provided with an application for\nauthorisation as a crypto-asset service provider? Please also state the reasons for your\nanswer."}], "evidence_b": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}], "rationale": "The EU MiCA passages (c51ad46265cea4e5::147::6214, c51ad46265cea4e5::2bc::cafa) focus on the requirements for obtaining authorisation as a Crypto-Asset Service Provider (CASP) and the information required by National Competent Authorities (NCAs). The MAS passages (20d526d712753652::403::be97) discuss internal processes for inaccurate representations and the application of general guidelines (like Fit and Proper Criteria) to licensees. There is no specific obligation in MiCA that conflicts with the MAS guidance on inaccurate representations or general licensing principles. The regimes regulate different aspects of financial services (MiCA specifically for crypto-asset services, MAS for general financial institutions and licensees)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:27:51Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b7af962134b6aabd32170b4c", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "rationale": "The evidence for AU_ASIC_CRYPTO focuses on the interpretation of the Corporations Act 2001 regarding crypto-assets as financial products and licensing requirements (chunk_ids abc9007e907ef318::3c9::4151, abc9007e907ef318::5a2::9ff3). The evidence for EU_EMD2 cites Directive (EU) 2022/2556 regarding digital operational resilience for the financial sector (chunk_id 85307f9e2a040982::14a::134d). The two regimes regulate distinct aspects of the financial sector—licensing and product classification under Australian law versus operational resilience under EU law—and there is no evidence of a specific obligation in one regime conflicting with a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:41:37Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.82, "record_type": "conflict", "pair_id": "conflict:09d1eb72ba9b7d68613b5465", "label": "conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "conflict_type": "recurring_friction", "severity": "medium", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::49d::c41e", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 44, "passage": "121 See Corporations Act, s 761E.\nAnnexure 1. Legal and regulatory framework | 41\n\nRegulator: AUSTRAC\nRelevant Legislation: AML/CTF Act\nDigital currency exchanges are regulated by AUSTRAC under the Anti Money Laundering and\nCounter Terrorism Financing (AML/CTF) Act for the purposes of preventing and detecting money\nlaundering and terrorism financing.\nDigital currency exchanges must register with AUSTRAC and meet AML/CTF compliance and\nreporting obligations (including Know Your Customer requirements).\nRegulator: ATO\nRelevant Legislation: Income Tax Act, Goods and Services Tax Act\nInvestors in crypto tokens and other market participants are subject to tax laws. If an entity is\ncarrying on a business in relation to digital currency, or as part of their existing business, or if\nthey are accepting digital currency as a payment in business, the entity needs to consider any\nGST consequences that may arise.\nTax implications for investors flow from the underlying nature of the rights and obligations\nattached to the asset and the personal circumstances of the investor. Crypto tokens will\ngenerally be capital assets, meaning there could be capital gains tax consequences.122"}, {"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}, {"chunk_id": "c4a92930a8caf822::3b4::f20d", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 126, "passage": "Part 9 of this instrument, be contained in a report under subsection 41(2) of the\nAct in relation to the suspicious matter reporting obligation. (3) The AUSTRAC CEO may, by notifiable instrument, specify a day for the\npurposes of subparagraph (1)(d)(ii).\n118 Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 Application, saving and transitional provisions Part 12\nSection 12-3\n12-3 Transitional-reports of threshold transactions to be in old form for first 3\nmonths after commencement\n(1) Subsections (2) and (3) apply if:\n(a) a reporting entity commences to provide, or provides, a designated service\nto a customer; and\n(b) the provision of the service involves a threshold transaction; and\n(c) the reporting entity is required under subsection 43(2) of the Act to give the\nAUSTRAC CEO a report of the transaction at any time during the period:\n(i) beginning at the commencement of this instrument; and\n(ii) ending on 30 June 2026."}], "rationale": "AU_ATO_CRYPTO (Australian Taxation Office crypto-asset tax framework — every disposal is a CGT event requiring identification of cost base, recordkeeping, and taxpayer reporting) and AU_AML_CTF (Australian AML/CTF Act — every designated-service interaction generates AUSTRAC reporting obligations and recordkeeping duty). The friction is recurring: every transaction on a regulated AU crypto-asset operator generates parallel obligations under both regimes — ATO tax-event tracking AND AUSTRAC AML data collection and reporting. Same shape as the careful-cohort labelled EU_DAC8 :: EU_AMLR_TFR recurring_friction (same-jurisdiction tax × AML scaling with transaction count).", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:48Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:36:06Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:6bfd2687d173c952ed1a1834", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "rationale": "The EU MiCA RTS passages discuss the notification obligations of financial entities providing crypto-asset services and the development of technical standards for CASPs (chunk_ids c51ad46265cea4e5::2f5::4513 and c51ad46265cea4e5::361::e378). In contrast, the Basel III General passages address the leverage ratio exposure measure, the treatment of fiduciary assets, and the calculation of expected losses and provisions for banks (chunk_ids 32afd37cade34f84::34b::8d30, 32afd37cade34f84::34e::4d5c, and 32afd37cade34f84::25d::6825). The obligations in MiCA regarding crypto-asset service provision do not overlap with the banking capital and leverage ratio obligations in Basel III. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:43:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9bd0a2e32684e0256169d568", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::4f2::95d6", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Such a warning may be\nprovided in a standardised format;\n(d) the investment firm complies with its obligations under Article 23.\n5. The investment firm shall establish a record that includes the document or documents agreed between the\ninvestment firm and the client that set out the rights and obligations of the parties, and the other terms on which\nthe investment firm will provide services to the client. The rights and duties of the parties to the contract may be\nincorporated by reference to other documents or legal texts.\n6. The investment firm shall provide the client with adequate reports on the service provided in a durable medium. Those reports shall include periodic communications to clients, taking into account the type and the complexity of\nfinancial instruments involved and the nature of the service provided to the client and shall include, where applicable, the\ncosts associated with the transactions and services undertaken on behalf of the client. When providing investment advice, the investment firm shall, before the transaction is made, provide the client with a\nstatement on suitability in a durable medium specifying the advice given and how that advice meets the preferences,\nobjectives and other characteristics of the retail client."}], "rationale": "The evidence from AU_AML_CTF (chunk 254ca2d92d196180::2ac::a5fe) outlines reporting obligations for suspicious matters, threshold transactions, and international funds transfer instructions. The evidence from EU_MIFID2 (chunk 28dfda0f6a6539b6::4f2::95d6) focuses on the investment firm's obligation to provide clients with adequate reports on the service provided, including periodic communications and costs. The obligations in the AU regime relate to anti-money laundering and counter-terrorism financing reporting, while the obligations in the EU regime relate to client reporting and suitability statements for investment services. These are distinct regulatory domains with no apparent overlap or conflict in obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:fe5d30997b2f1b59432b98d4", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}], "rationale": "AU_ASIC_CRYPTO (regime A) addresses when crypto-assets are financial products under Australia's Corporations Act and require AFSL-style licensing of providers. SG_PSA_GENERAL (regime B) addresses payment-service licensing under Singapore's PSA. Both cover crypto licensing in their jurisdictions, but they apply different licensing perimeters: financial-product-status (A) vs payment-service-activity (B). The cited passages don't impose conflicting obligations on the same entity action."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:42:12Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:38bed177e146b2005f15d222", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::4f1::4905", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "Treasury received substantial feedback\nfrom a range of stakeholders with industry-wide support for clarity on the regulatory settings for crypto\nassets. In particular, key stakeholders flagged the need to prioritise the 'token mapping' work, which\ninvolves reviewing a range of crypto assets to identify how they fit within the existing regulatory framework. Accordingly, to commence the reform agenda, I will prioritise the complex 'token mapping' work in 2022. Token mapping is a foundational piece of work to support Government to identify how crypto assets and\nrelated services ought to be regulated. It will also importantly aid the development of a licensing framework\nby assisting in demarcating the perimeter between financial product crypto assets (already the subject of\nfinancial services laws) and non-financial product crypto assets (that may warrant a separate crypto asset\nregulatory framework). Parliament House Canberra ACT 2600 Australia\nOFFICIAL: Sensitive OFFICIAL: Sensitive Subject to your agreement, I propose to announce the reform agenda, commence stakeholder consultations\nand release a public consultation paper on token mapping in 2022 (as indicated in Treasury's earlier\nconsultation paper on crypto licensing and custody requirements)."}, {"chunk_id": "e6bb47e92e88e16c::37a::29f6", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 12, "passage": "16. After token mapping, licensing and custody reforms are the logical next step for crypto reforms\nin Australia. The identification of appropriate obligations and operational standards for crypto\nasset service providers and how they safe-keep assets for customers is a key step for consumer\nprotection; ensuring consumers do not lose assets to avoidable business failure or misuse of\nassets by the provider.\n\n17. The Government will release a consultation paper proposing a licensing and custody framework\nfor crypto asset service providers in mid-2023 to allow for sufficient consultation prior to the\nintroduction of legislation. The paper will reflect ongoing work and consultation in this area and\nleverage the findings from the token mapping exercise. The responses to the following\nquestions will help inform the general direction of future policy and potential consumer\nprotections."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The AU_TREASURY_DAP passages describe Australia's domestic regulatory agenda for crypto assets, specifically token mapping and future licensing frameworks (chunk_ids d75262e404517e0c::4f1::4905, e6bb47e92e88e16c::37a::29f6). The INT_IOSCO_GENERAL passages are methodological references to IOSCO's general objectives and principles for securities regulation, including cross-border disclosure standards and cooperation (chunk_id f173909614befd49::455::1a1a). The regimes regulate different domains: one is a specific national legislative reform proposal for crypto assets, while the other is a general international standard-setting body's methodology for securities regulation. There is no specific obligation in the Australian crypto reform agenda that conflicts with the general IOSCO principles cited."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:53:04Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b312ca9065cabd963f2abcf3", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "rationale": "The AU_PRIVACY passages regulate the cross-border disclosure of personal information, requiring entities to ensure overseas recipients comply with Australian Privacy Principles (APPs) and providing exceptions for consent or permitted general situations (e.g., safety threats) [e9f6b0a9e797777d::5d6::e5ff, e9f6b0a9e797777d::4ba::1af3]. The EU_PSD2 passages regulate payment services, specifically strong customer authentication (SCA) and the protection of payment service users' personalised security credentials [adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b]. The obligations are distinct: one governs data privacy and cross-border transfer, while the other governs payment security and authentication. There is no specific obligation in AU_PRIVACY that pushes against a specific obligation in EU_PSD2, nor do the regimes regulate the same subject matter. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:43:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:393dd43902756929bc2ee8a4", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "rationale": "The evidence for Regime A (AU_APRA_CPS230) focuses on operational risk management, resilience, and the management of service providers to ensure critical operations continue through disruptions. The evidence for Regime B (EU_REVERSE_SOLICITATION) focuses on the regulatory treatment of crypto-asset services provided by third-country firms to clients who initiate the relationship (reverse solicitation). The obligations in Regime A relate to the internal risk management and continuity of operations for an APRA-regulated entity, whereas the obligations in Regime B relate to the authorization requirements and solicitation rules for crypto-asset services in the EU. The two regimes regulate distinct domains of financial activity and do not impose conflicting obligations on the same entity or transaction type."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:d5f5ac8b6be9b693469a6449", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::25d::6825", "source_doc": "d424.pdf", "page": 85, "passage": "150. At national supervisory discretion, banks using both the standardised and IRB approaches may\nrely on their internal methods for allocating general provisions for recognition in capital under either the\nstandardised or IRB approach, subject to the following conditions. Where the internal allocation method\nBasel III: Finalising post-crisis reforms 81\n\nis made available, the national supervisor will establish the standards surrounding their use. Banks will\nneed to obtain prior approval from their supervisors to use an internal allocation method for this purpose.\n\n3. Treatment of EL and provisions"}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "ba862e1f095bceac::1a6::1f0e", "source_doc": "FATF Recommendations 2012.pdf.coredownload.inline.pdf", "page": 79, "passage": "4. A country need not impose a separate licensing or registration system with respect to natural\nor legal persons already licensed or registered as financial institutions (as defined by the FATF\nRecommendations) within that country, which, under such license or registration, are\npermitted to perform VASP activities and which are already subject to the full range of\napplicable obligations under the FATF Recommendations."}], "rationale": "INT_BASEL_GENERAL (Basel III prudential framework — leverage ratio, capital provisions) and INT_FATF_VASP (FATF VASP AML guidance). International standards bodies addressing distinct but coordinated concerns (prudential vs AML). Aligned pillars of international financial regulation."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:42:41Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:35602237f57f2b095f647a6e", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "018117ef1e757630::4b5::9ef5", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Guidelines\n• MAS' surveillance efforts are • Existing VASPs operating in\nfocused on: (a) detecting and Singapore were required to notify\nLicensing\ndeterring unlicensed DPT activities MAS and submit licence\nSurveillance and\nin Singapore; and (b) leveraging applications by 28 Jul 2020.\ndata and blockchain analytics to Supervision\nidentify higher risk entities. • Applicants expected to\ndemonstrate understanding and\nability to mitigate ML/TF risks. Slide 5 (III) AML/CFT requirements for DPT sector\nAML/CFT requirements for digital payment token (DPT) service in Singapore\n• AML/CFT requirements are set out in MAS Notice PSN02 (issued 5 Dec 2019) and Guidelines to PSN02 (issued on 16 Mar 2020). Amendments to the Payment Services Act were passed in Parliament in Jan 2021 to expand the scope of DPT services and\nfurther updates to Notice PSN02 and Guidelines are in train to apply AML/CFT requirements to the newly scoped-in DPT services.\n• Entities that (a) deal in DPT; (b) facilitate the exchange of DPT; (c) facilitate the transmission of DPT; (d) and/or provide custodian\nwallet services, will therefore be required to be licensed as DPT service providers, and comply with the AML/CFT requirements."}], "rationale": "The Australian regime (Regime A) regulates reporting entities and reporting obligations under the AML/CTF Act, including obligations for remittance dealers and cash dealers. The Singapore regime (Regime B) regulates digital payment token (DPT) service providers under the Payment Services Act and MAS Notice PSN02. The passages confirm that the Singapore regime applies to entities dealing in, exchanging, transmitting, or providing custodian wallet services for DPTs, and requires them to comply with AML/CFT requirements. While both regimes share the goal of AML/CFT compliance, the specific obligations and regulated entities (reporting entities vs. DPT service providers) are distinct. The evidence shows no specific obligation in Regime A that pushes against a specific obligation in Regime B; rather, they regulate different sectors (general financial services vs. digital payment tokens) within the broader AML/CFT framework."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:5d72bbdd1c46c8a69796ad0a", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "f916d87ae90e8ed3::3ed::9039", "source_doc": "Guidance-RBA-money-value-transfer-services.pdf.coredownload.pdf", "page": null, "passage": "GUIDANCE FOR A RISK-BASED APPROACH\nMONEY OR VALUE TRANSFER\nSERVICES\nFEBRUARY 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance for a Risk-Based Approach for Money or Value Transfer Services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/rba-money-or-value-transfer.html\n© 2016 FATF/OECD."}], "rationale": "AU_TRAVEL_RULE (AU's FATF travel-rule consultation for DCE providers — Australia has not yet implemented but DCE providers comply with AML/CTF obligations including customer identification) and FATF_R16 (FATF Recommendation 16 — the underlying international travel-rule standard). The AU framework explicitly references and is moving toward FATF R16 implementation. Reinforcing rather than conflicting; AU is implementing the FATF standard."}
+{"annotator_id": 10116, "annotated_at": "2026-05-26T01:13:52Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:8e8aeccfc312689a6686d231", "label": "conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU Treasury Digital Asset Platforms"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title V (CASP)"}, "conflict_type": "structural_unresolved", "severity": "high", "evidence_a": [{"chunk_id": "550958b067dc6726::51b::b09b", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 6, "passage": "5 KordaMentha, 'Token mapping: Response to Treasury consultation paper', March 2023. Introduction | 3 laws, digital asset platforms that do not deal in financial products are not subject to financial services\nlaws. The Government intends to introduce a regulatory framework aimed at addressing the significant risks\nand potential harms associated with digital asset platforms, while fostering innovation and safe usage\nof digital assets and distributed ledger technology. The framework outlined in this paper proposes to\nregulate digital asset platforms within the existing Australian financial services laws, while ensuring all\nconsumers and businesses have the opportunity to safely explore and share in any benefits of the\ntechnology. Key terms and concepts used throughout this paper\nUnderstanding the policy problem and the proposed regulatory solution requires an understanding of\nseveral key concepts and terms that are used throughout this paper. These concepts and terms aim to\nreduce the complexity of the paper's content, which necessarily covers topics across industries,\ntechnologies, and regulatory frameworks. They include some broad generalisations for descriptive\nconvenience and some precise technical descriptions for topics stakeholders have identified as causing\nregulatory uncertainty."}, {"chunk_id": "e6bb47e92e88e16c::2af::609f", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 39, "passage": "117. The token mapping framework defines the concepts of 'tokens', 'token systems' and 'functions'.\nA crypto token performs the record keeping role. It is analogous to a physical token or an entry\nin a registry. A token system is the business or social protocol, or mechanism. It is the steps\ntaken to perform a function in relation to crypto tokens. A function is the product or benefit\nprovided by a token system.\nInsights\n\n118. The crypto ecosystem is not a homogenous industry sector and crypto assets are not a\nhomogenous asset class. The process of assessing crypto related products against the functional\nperimeter is no different than the process for assessing any other product."}, {"chunk_id": "e6bb47e92e88e16c::37a::29f6", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 12, "passage": "16. After token mapping, licensing and custody reforms are the logical next step for crypto reforms\nin Australia. The identification of appropriate obligations and operational standards for crypto\nasset service providers and how they safe-keep assets for customers is a key step for consumer\nprotection; ensuring consumers do not lose assets to avoidable business failure or misuse of\nassets by the provider.\n\n17. The Government will release a consultation paper proposing a licensing and custody framework\nfor crypto asset service providers in mid-2023 to allow for sufficient consultation prior to the\nintroduction of legislation. The paper will reflect ongoing work and consultation in this area and\nleverage the findings from the token mapping exercise. The responses to the following\nquestions will help inform the general direction of future policy and potential consumer\nprotections."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::3e9::b448", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 81, "passage": "Competent authorities shall refuse authorisation as a crypto-asset service provider where there are objective and\ndemonstrable grounds that:\n(a) the management body of the applicant crypto-asset service provider poses a threat to its effective, sound and\nprudent management and business continuity, and to the adequate consideration of the interest of its clients and\nthe integrity of the market, or exposes the applicant crypto-asset service provider to a serious risk of money\nlaundering or terrorist financing;\n(b) the members of the management body of the applicant crypto-asset service provider do not meet the criteria set out\nin Article 68(1);\n(c) the shareholders or members, whether direct or indirect, that have qualifying holdings in the applicant crypto-asset\nservice provider do not meet the criteria of sufficiently good repute set out in Article 68(2);\n(d) the applicant crypto-asset service provider fails to meet or is likely to fail to meet any of the requirements of this\nTitle.\n11."}, {"chunk_id": "491a2f0014d56ffb::452::8eaf", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 63; or\n(b) a credit institution, central securities depository, investment firm, market operator, electronic money institution,\nUCITS management company, or an alternative investment fund manager that is allowed to provide crypto-asset\nservices pursuant to Article 60. EN\nL 150/114 2. Crypto-asset service providers authorised in accordance with Article 63 shall have a registered office in a Member\nState where they carry out at least part of their crypto-asset services. They shall have their place of effective management\nin the Union and at least one of the directors shall be resident in the Union.\n3. For the purposes of paragraph 1, point (a), other undertakings that are not legal persons shall only provide crypto-\nasset services if their legal form ensures a level of protection for third parties' interests equivalent to that afforded by\nlegal persons and if they are subject to equivalent prudential supervision appropriate to their legal form.\n4. Crypto-asset service providers authorised in accordance with Article 63 shall at all times meet the conditions for\ntheir authorisation.\n5."}, {"chunk_id": "491a2f0014d56ffb::48f::be78", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 79, "passage": "Article 62\nApplication for authorisation as a crypto-asset service provider\n1.\nLegal persons or other undertakings that intend to provide crypto-asset services shall submit their application for\nan authorisation as a crypto-asset service provider to the competent authority of their home Member State.\n2.\nThe application referred to in paragraph 1 shall contain all of the following information:\n(a) the name, including the legal name and any other commercial name used, the legal entity identifier of the applicant\ncrypto-asset service provider, the website operated by that provider, a contact email address, a contact telephone\nnumber and its physical address;\nEN\nL 150/118\n\n(b) the legal form of the applicant crypto-asset service provider;\n(c) the articles of association of the applicant crypto-asset service provider, where applicable;\n(d) a programme of operations, setting out the types of crypto-asset services that the applicant crypto-asset service\nprovider intends to provide, including where and how those services are to be marketed;\n(e) proof that the applicant crypto-asset service provider meets the requirements for prudential safeguards set out in"}], "rationale": "Treasury's proposed Digital Asset Platforms regime (Australia) and MiCA Title V (EU) each establish a jurisdiction-specific licensing regime for the same economic activity — operating a platform that custodies, exchanges, or otherwise services crypto-assets for retail customers. The tension is structural: neither regime contains an equivalence, mutual-recognition, or transit pathway that lets an entity authorised under one operate under the other without a separate, full authorisation. An AU-licensed DAP operator seeking to provide crypto-asset services to EU clients must obtain a separate MiCA Title V CASP authorisation; an EU-authorised CASP cannot transit its authorisation to operate as a DAP in Australia. The pattern is the same as AUDD-vs-MiCA-Title-IV on the token side (example subgraph 02), but at the entity/CASP-licensing layer. Unlike operationally-resolvable conflicts, there is no published mechanism (no SCC-equivalent, no adequacy decision) that bridges the gap — the only path is to obtain authorisation in each jurisdiction separately.", "compliant_paths": ["Establish a separately-licensed entity in each jurisdiction (AU subsidiary for DAP + EU subsidiary for MiCA CASP).", "Restrict services to a single jurisdiction's clients and rely on territoriality + narrow exceptions (e.g. EU reverse solicitation under Art. 61) — accepting that these are exceptions, not authorisation substitutes."], "out_of_scope_assumptions": ["DAP regime is treated as finalised per the 2023 Treasury proposal; the analysis would change if Australia subsequently enters a mutual-recognition arrangement with the EU.", "Reverse-solicitation handling is bounded to genuine client-initiated requests under ESMA's narrow interpretation."], "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:29:47Z", "decision": "accept", "notes": "", "original_conflict_type": "structural_unresolved", "original_severity": "high", "original_review_status": "reviewed_accept"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:d0f75f6ccafbcbd1be9deab7", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::25d::6825", "source_doc": "d424.pdf", "page": 85, "passage": "150. At national supervisory discretion, banks using both the standardised and IRB approaches may\nrely on their internal methods for allocating general provisions for recognition in capital under either the\nstandardised or IRB approach, subject to the following conditions. Where the internal allocation method\nBasel III: Finalising post-crisis reforms 81\n\nis made available, the national supervisor will establish the standards surrounding their use. Banks will\nneed to obtain prior approval from their supervisors to use an internal allocation method for this purpose.\n\n3. Treatment of EL and provisions"}], "rationale": "AU_APRA_CPS230 (APRA Operational Risk Management standard) and INT_BASEL_GENERAL (Basel III framework — including operational-risk capital and risk-management principles). APRA implements Basel-aligned prudential standards; CPS 230 sits within the broader Basel-influenced operational-risk framework. Aligned by design."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:f20f5e23c45c95905ba99519", "label": "conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "conflict_type": "recurring_friction", "severity": "medium", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::2bc::cafa", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 9, "passage": "19. Article 62(4) of MiCA sets out that NCAs must not require an applicant CASP to provide\nany information referred to in Article 62(2) of MiCA that they have already received under\nthe respective authorisation procedures in accordance with Directive 2009/110/EC4,\n2014/65/EU5 or (EU) 2015/23666, or pursuant to national law applicable to crypto-asset\nservices prior to the date of entry into force of MiCA, provided that such previously\nsubmitted information or documents are still up-to-date.\n\n3.2 Feedback statement\nQ2: Do you agree with the list of information to be provided with an application for\nauthorisation as a crypto-asset service provider? Please also state the reasons for your\nanswer."}], "rationale": "EU_PSD2 (Article 97 strong-customer-authentication on every payment account access / electronic transaction) and EU_MICA_TITLE_V_CASP (MiCA CASP authorisation with operational and conduct obligations). MiCA-authorised CASPs handling fiat-rail transactions are subject to PSD2's SCA requirements on every authentication event. The friction is recurring: every transaction triggers PSD2's per-event obligation in addition to MiCA's per-relationship obligations.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:44Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:51:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:ff4534be67d8d0f5025c5b0b", "label": "non_conflict", "regime_a": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}], "rationale": "The EU regime (Regime A) regulates the specific licensing and solicitation requirements for crypto-asset service providers (CASPs) operating in the EU, specifically addressing 'reverse solicitation' exemptions under MiCA. The FATF regime (Regime B) provides global AML/CFT standards and guidance, including on digital identity and virtual assets. The passages provided for Regime B are general introductory or bibliographic references to FATF documents (e.g., 'DIGITAL IDENTITY', 'FATF REPORT', 'GUIDANCE FOR A RISK-BASED APPROACH') and do not contain specific obligations regarding solicitation, licensing, or the reverse solicitation exemption. Because the obligations in Regime A do not push against specific obligations in Regime B, and the FATF passages do not address the specific regulatory tension of reverse solicitation, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:4d4035addf6674d054efeb24", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title V (CASP)"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiFID II"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::eb::35e6", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 59\nAuthorisation\n1.\nA person shall not provide crypto-asset services, within the Union, unless that person is:\n(a) a legal person or other undertaking that has been authorised as crypto-asset service provider in accordance with"}, {"chunk_id": "491a2f0014d56ffb::452::8eaf", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 63; or\n(b) a credit institution, central securities depository, investment firm, market operator, electronic money institution,\nUCITS management company, or an alternative investment fund manager that is allowed to provide crypto-asset\nservices pursuant to Article 60. EN\nL 150/114 2. Crypto-asset service providers authorised in accordance with Article 63 shall have a registered office in a Member\nState where they carry out at least part of their crypto-asset services. They shall have their place of effective management\nin the Union and at least one of the directors shall be resident in the Union.\n3. For the purposes of paragraph 1, point (a), other undertakings that are not legal persons shall only provide crypto-\nasset services if their legal form ensures a level of protection for third parties' interests equivalent to that afforded by\nlegal persons and if they are subject to equivalent prudential supervision appropriate to their legal form.\n4. Crypto-asset service providers authorised in accordance with Article 63 shall at all times meet the conditions for\ntheir authorisation.\n5."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}, {"chunk_id": "28dfda0f6a6539b6::49c::69f4", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 53, "passage": "Member States shall require that investment firms and market operators operating an MTF or an OTF establish,\npublish and maintain and implement transparent and non-discriminatory rules, based on objective criteria, governing\naccess to its facility.\n4. Member States shall require that investment firms and market operators operating an MTF or an OTF have\narrangements to identify clearly and manage the potential adverse consequences for the operation of the MTF or OTF,\nor for the members or participants and users, of any conflict of interest between the interest of the MTF, the OTF, their\nowners or the investment firm or market operator operating the MTF or OTF and the sound functioning of the MTF or\nOTF.\n5. Member States shall require that investment firms and market operators operating an MTF or OTF comply with\nArticles 48 and 49 and have in place all the necessary effective systems, procedures and arrangements to do so.\n6. Member States shall require that investment firms and market operators operating an MTF or an OTF clearly inform\nits members or participants of their respective responsibilities for the settlement of the transactions executed in that\nfacility."}], "rationale": "MiCA Title V CASP rules are explicitly modelled on MiFID II investment-firm authorisation and conduct. MiCA Article 60 carves out incumbent regulated entities including MiFID II investment firms — those entities may provide crypto-asset services on the strength of their existing authorisation, subject to a notification regime. The two regimes are aligned by design with MiCA explicitly building on MiFID II concepts (best execution, suitability) carried into the crypto context.", "would_conflict_if": ["A MiCA Level-2 RTS prescribed a CASP-specific best-execution rule incompatible with MiFID II Art. 27 — Level-2 work is coordinated to avoid this."]}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:1c73030a0c07973ac5550d63", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "regime_b": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "NIS 2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3a1785f95cb37b3c::336::8d0b", "source_doc": "AMLA_Regulation_EU_2024-1620.pdf", "page": 32, "passage": "The list of\nthe selected obliged entities shall be published by the Authority without undue delay upon completion of the selection\nprocess. The Authority shall commence direct supervision of the selected obliged entities six months after publication of\nthe list.\n5. Prior to the publication of the list of the selected obliged entities, the Authority shall inform the relevant\nnon-AML/CFT authorities of the outcomes of the process of assessment and classification of inherent and residual risk of\nthe obliged entities subject to assessment.\n6. A selected obliged entity shall remain subject to direct supervision by the Authority until the Authority commences\nthe direct supervision of selected obliged entities based on a list established for the subsequent selection period which no\nlonger includes that obliged entity."}], "evidence_b": [{"chunk_id": "20d29e9c5300ae10::265::c962", "source_doc": "NIS2_Directive_EU_2022-2555.pdf", "page": 17, "passage": "(83) Essential and important entities should ensure the security of the network and information systems which they use\nin their activities. Those systems are primarily private network and information systems managed by the essential\nand important entities' internal IT staff or the security of which has been outsourced. The cybersecurity risk-\nmanagement measures and reporting obligations laid down in this Directive should apply to the relevant essential\nand important entities regardless of whether those entities maintain their network and information systems\ninternally or outsource the maintenance thereof."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLA Regulation establishing the AML supervisor and EU NIS 2 horizontal cybersecurity directive operate in disjoint regulatory domains at the obligation level. AML supervisor vs horizontal cybersecurity directive — disjoint subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:4dea4b97ad79935ced1d3f77", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "Market Abuse Regulation"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3a1785f95cb37b3c::336::8d0b", "source_doc": "AMLA_Regulation_EU_2024-1620.pdf", "page": 32, "passage": "The list of\nthe selected obliged entities shall be published by the Authority without undue delay upon completion of the selection\nprocess. The Authority shall commence direct supervision of the selected obliged entities six months after publication of\nthe list.\n5. Prior to the publication of the list of the selected obliged entities, the Authority shall inform the relevant\nnon-AML/CFT authorities of the outcomes of the process of assessment and classification of inherent and residual risk of\nthe obliged entities subject to assessment.\n6. A selected obliged entity shall remain subject to direct supervision by the Authority until the Authority commences\nthe direct supervision of selected obliged entities based on a list established for the subsequent selection period which no\nlonger includes that obliged entity."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::1bd::d04c", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 14\nProhibition of insider dealing and of unlawful disclosure of inside information\nA person shall not:\n(a) engage or attempt to engage in insider dealing;\n(b) recommend that another person engage in insider dealing or induce another person to engage in insider dealing; or\n(c) unlawfully disclose inside information.\n\nArticle 15\nProhibition of market manipulation\nA person shall not engage in or attempt to engage in market manipulation."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLA Regulation establishing the AML supervisor and EU Market Abuse Regulation operate in disjoint regulatory domains at the obligation level. AML supervisor vs market-abuse regulation — disjoint domains. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.78, "record_type": "non_conflict", "pair_id": "non_conflict:267da79d0b0835f41810bea4", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLD6"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}], "rationale": "EU_AMLD6 (EU's anti-money-laundering directive framework, latest iteration) and FATF_R16 (FATF Recommendation 16 — travel rule for VAs/VASPs). EU AMLD6 and the accompanying AMLR/TFR are the EU's implementation of FATF Recommendations including R16; the two are designed to align. Reinforcing rather than conflicting relationship."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.82, "record_type": "conflict", "pair_id": "conflict:867d295a9f087aa90dcdd413", "label": "conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "f9ea5fb6d86aeb75::62c::a60c", "source_doc": "APP_Guidelines_Consolidated.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.3, October 2025\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake such steps as are reasonable in the circumstances to ensure that the overseas recipient\ndoes not breach the APPs (other than APP 1) in relation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, to facilitate the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take such steps as are reasonable in the\ncircumstances to ensure that the recipient does not breach the APPs in relation to that\ninformation."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}], "rationale": "AU_PRIVACY (APP 8 cross-border disclosure restrictions) and FATF_R16 (FATF Recommendation 16 — travel rule requiring originator/beneficiary information for VA transfers). FATF R16 implementations require sharing personal data of senders/recipients across borders; APP 8 restricts overseas disclosure. Operationally resolvable via APP 6.2(b) (required by law) when AU implements R16 via AML/CTF framework. Same cross-jurisdictional AML-privacy shape.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:55Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:32:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:582e63a394673e56a7e41e1b", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}, {"chunk_id": "c51ad46265cea4e5::361::e378", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 16, "passage": "57. ESMA is mandated in Article 84(4) of MiCA to develop, in close cooperation with EBA,\ndraft regulatory technical standards (RTS) on the detailed content of the information for\nthe assessment of proposed acquisitions of qualifying holdings in CASPs. The aim of\nthis draft RTS is to specify the detailed content of the information that direct or indirect\nproposed acquirers must provide to national competent authorities (NCAs) when\nnotifying the intended acquisition. This should ensure a harmonised approach to the\nassessment across Member States in the EU of the intended acquisition of qualifying\nholdings in CASPs.\n\n58. The RTSs are applicable to proposed acquirers of qualifying holdings in CASPs, as well\nas NCAs as designated under Article 93(1) of MiCA that will conduct the assessment of\nthe intended acquisition in accordance with Article 83(4) of MiCA."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "The EU MiCA RTS passages describe the development of technical standards for crypto-asset service providers (CASP) and notification requirements (chunk_ids c51ad46265cea4e5::2f5::4513 and c51ad46265cea4e5::361::e378). The Singapore foundational legislation passage discusses MAS's intention to align with international standards and considers the regulatory scope of securities-based crypto tokens (SCS), specifically mentioning that SCS issued under EU MiCA regulation may warrant recognition (chunk_id 7c04f2a0bd85290a::413::fc6a). The regimes regulate the same general topic (crypto-assets) but the EU passage outlines internal EU technical standards development, while the Singapore passage discusses the application of Singaporean regulatory powers to foreign tokens and international alignment. There is no evidence of a specific obligation in MiCA RTS that conflicts with a specific obligation in Singaporean foundational legislation; rather, the Singapore passage acknowledges the EU framework as a potential basis for recognition. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:38:43Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:05346f94c1b37ded831bad94", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}], "rationale": "The AU_TREASURY_DAP passages discuss the Australian government's 'token mapping' exercise to identify how crypto assets fit into the financial services framework and the subsequent development of licensing and custody reforms. The EU_MIFID2 passages describe obligations for investment firms regarding the product approval process, suitability assessments, and information disclosure for financial instruments. The obligations in the EU regime apply to investment firms and financial instruments, whereas the Australian regime addresses the regulatory perimeter for crypto assets and service providers. The passages describe different regulatory domains and do not contain specific obligations that push against one another."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.88, "record_type": "conflict", "pair_id": "conflict:71fd9286d3bc45802bb7222a", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}, {"chunk_id": "f916d87ae90e8ed3::3ed::9039", "source_doc": "Guidance-RBA-money-value-transfer-services.pdf.coredownload.pdf", "page": null, "passage": "GUIDANCE FOR A RISK-BASED APPROACH\nMONEY OR VALUE TRANSFER\nSERVICES\nFEBRUARY 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance for a Risk-Based Approach for Money or Value Transfer Services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/rba-money-or-value-transfer.html\n© 2016 FATF/OECD."}], "rationale": "EU_GDPR (Article 44+ cross-border data transfer principles) and FATF_R16 (FATF Recommendation 16 — travel rule for VAs requiring sharing of originator/beneficiary personal data across borders for VA transfers). FATF R16 implementations in EU (TFR) mandate the data sharing; GDPR Chapter V restricts. Operationally resolvable via GDPR Art. 6(1)(c) plus Chapter V mechanism. Same conflict shape as the labelled EU TFR ↔ EU GDPR conflict in the careful cohort.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:50Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:19:43Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:bf855ce0ed8eaa00c2694e49", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}, {"chunk_id": "c51ad46265cea4e5::462::80d8", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 76, "passage": "6.5 Annex V - Draft RTS pursuant to Article 62(5) of MiCA\nCOMMISSION DELEGATED REGULATION (EU) .../...\nof XXX\nsupplementing Regulation (EU) 2023/1114 of the European Parliament and of the\nCouncil with regard to regulatory technical standards specifying the information to be\nincluded in an application for authorisation as crypto-asset service provider\n(Text with EEA relevance)\nTHE EUROPEAN COMMISSION,\nHaving regard to the Treaty on the Functioning of the European Union,\nHaving regard to Regulation (EU) 2023/1114 of the European Parliament and of the Council\nof 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2012\nand (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/193718, and in particular\nArticle 62(5), third subparagraph, thereof,\nWhereas:\n(1) The information to be provided in an application for authorisation as crypto-asset service\nprovider should be sufficiently detailed and comprehensive to enable competent\nauthorities to assess whether an applicant meets the applicable requirements laid down\nin Title V and, where relevant, Title VI of Regulation (EU) 2023/1114."}], "rationale": "The AU_TTR_THRESHOLD regime regulates the reporting of physical cash transactions exceeding A$10,000 to AUSTRAC (chunk_ids 6dfe4e63b9fb3c74::3bc::1a3f, 254ca2d92d196180::377::d0c6). The EU_MICA regime regulates the provision of crypto-asset services and the authorisation of crypto-asset service providers (chunk_ids f9082873c5d9ba9d::302::bbe0, c51ad46265cea4e5::462::80d8). The obligations in the Australian regime relate to physical currency reporting thresholds, while the obligations in the EU regime relate to the licensing and conduct of crypto-asset service providers. There is no specific obligation in MiCA that conflicts with the AUSTRAC reporting requirement for physical cash transfers, nor do the regimes regulate the same subject matter in a way that creates a friction point."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:45:46Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:6309564d28bedbe334dcccdb", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::353::debc", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 14, "passage": "(69)\nThe crypto-asset white paper drawn up by an issuer of e-money tokens should contain all information concerning\nthat issuer and the offer of e-money tokens or their admission to trading that is necessary to enable prospective\nbuyers to make an informed purchase decision and understand the risks relating to the offer of e-money tokens.\nThe crypto-asset white paper should also expressly refer to the right of holders of e-money tokens to redeem their\ne-money tokens for funds denominated in the official currency that the e-money tokens reference at par value\nand at any time.\n\n(70)\nWhere an issuer of e-money tokens invests the funds received in exchange for e-money tokens, such funds should\nbe invested in assets denominated in the same official currency as the one that the e-money token is referencing\nin order to avoid cross-currency risks."}], "rationale": "The obligations in the Australian Privacy Principle 8 (AU_PRIVACY) govern the cross-border disclosure of personal information to overseas recipients, requiring reasonable steps to ensure compliance and accountability for mishandling (chunk_ids e9f6b0a9e797777d::5d6::e5ff, e9f6b0a9e797777d::4ba::1af3). In contrast, the EU MICA Title IV EMT provisions regulate the liability of issuers of e-money tokens for information provided in crypto-asset white papers and the content of those white papers (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::353::debc). The two regimes regulate distinct subject matter—data protection and cross-border data flows versus financial product disclosure and liability for token issuers—and do not impose conflicting obligations on the same entity or transaction type."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:46:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:8c6b1451f19ee5dc6721aaea", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "PSD2"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}, {"chunk_id": "85307f9e2a040982::36a::b013", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 38, "passage": "27.12.2022 EN Official Journal of the European Union L 333/39\n(h) implement, as appropriate, relevant operational conclusions resulting from the tests referred to in point (g) and from\npost-incident analysis into the ICT risk assessment process and develop, according to needs and ICT risk profile, ICT\nsecurity awareness programmes and digital operational resilience training for staff and management.\n2. The ICT risk management framework referred to in paragraph 1, second subparagraph, point (a), shall be documented\nand reviewed periodically and upon the occurrence of major ICT-related incidents in compliance with supervisory\ninstructions. It shall be continuously improved on the basis of lessons derived from implementation and monitoring. A\nreport on the review of the ICT risk management framework shall be submitted to the competent authority upon its\nrequest.\n3."}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::43b::29d2", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 6, "passage": "(30) The personalised security credentials used for secure customer authentication by the payment service user or by the\npayment initiation service provider are usually those issued by the account servicing payment service providers.\nPayment initiation service providers do not necessarily enter into a contractual relationship with the account\nservicing payment service providers and, regardless of the business model used by the payment initiation service\nproviders, the account servicing payment service providers should make it possible for payment initiation service\nproviders to rely on the authentication procedures provided by the account servicing payments service providers to\ninitiate a specific payment on behalf of the payer.\n\n(31) When exclusively providing payment initiation services, the payment initiation service provider does not at any\nstage of the payment chain hold the user's funds. When a payment initiation service provider intends to provide\npayment services in relation to which it holds user funds, it should obtain full authorisation for those services."}], "rationale": "DORA applies to payment service providers (PSPs) as a class of EU financial entity; PSD2 authorises and supervises those same PSPs. DORA Art. 6 imposes ICT risk-management framework duties; PSD2 Art. 97 imposes Strong Customer Authentication duties. The two regimes are aligned by design — PSD2 supplies the payments-specific overlay, DORA supplies the horizontal ICT-resilience overlay. No DORA obligation pushes against any PSD2 obligation. Easy hard negative.", "would_conflict_if": ["DORA's ICT third-party register obligation prevented PSPs from using outsourced SCA providers — DORA's framework is designed to permit such arrangements with documentation, not prohibit them."]}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T06:30:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.75, "record_type": "conflict", "pair_id": "conflict:164df5ab4215c95bcb56bc08", "label": "conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU AML/CTF Act + Rules"}, "regime_b": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU TTR Threshold"}, "conflict_type": "recurring_friction", "severity": "medium", "evidence_a": [{"chunk_id": "254ca2d92d196180::369::b111", "source_doc": "Anti-Money Laundering act 2006.pdf", "page": 98, "passage": "Part 2 Identification procedures etc. Division 2 Identification procedures for certain pre-commencement customers\nSection 29\n(b) after the commencement of this section, a suspicious matter\nreporting obligation arises for the reporting entity in relation\nto the customer. Note 1: For suspicious matter reporting obligation, see section 41. Note 2: For tipping-off offences, see section 123. Requirement\n(2) The reporting entity must:\n(a) take such action as is specified in the AML/CTF Rules; and\n(b) do so within the time limit allowed under the AML/CTF\nRules. Civil penalty\n(3) Subsection (2) is a civil penalty provision. Interpretation\n(4) For the purposes of this section, assume that Part 1 had been in\nforce at all material times before the commencement of this\nsection.\n80 Anti-Money Laundering and Counter-Terrorism Financing Act 2006 Identification procedures etc."}, {"chunk_id": "254ca2d92d196180::43c::0a91", "source_doc": "Anti-Money Laundering act 2006.pdf", "page": 98, "passage": "Part 2\nIdentification procedures for certain low-risk services Division 3\nSection 30\nDivision 3-Identification procedures for certain low-risk\nservices\n30 Identification procedures for certain low-risk services\nScope\n(1) This section applies to the provision by a reporting entity of a\ndesignated service to a customer if, under the AML/CTF Rules, the\nservice is taken to be a low-risk designated service. (2) Sections 32 and 34 do not apply to the provision by the reporting\nentity of the designated service to the customer. Note: For special rules about verification of identity etc., see section 31.\n31 Verification of identity of low-risk service customer etc. Scope\n(1) This section applies to a reporting entity if:\n(a) at a particular time (the relevant time), the reporting entity\ncommences to provide a designated service to a customer;\nand\n(b) under the AML/CTF Rules, the service is taken to be a\nlow-risk designated service; and\n(c) at the relevant time or a later time, a suspicious matter\nreporting obligation arises for the reporting entity in relation\nto the customer."}], "evidence_b": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "6dfe4e63b9fb3c74::32b::fd2f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "Reporting structuring Related legislation Part 3, Division 3 (Sections 43 and 44) of the AML/CTF Act (latest version) - Threshold\ntransactions Chapter 19 of the AML/CTF Rules (latest version) - Reportable details for threshold\ntransactions The content on this website is general and is not legal advice. Before you make a decision or\ntake a particular action based on the content on this website, you should check its accuracy,\ncompleteness, currency and relevance for your purposes. You may wish to seek independent\nprofessional advice. https://www.austrac.gov.au/business/core-guidance/reporting/reporting-transactions-10000-and-over-threshold-transaction-reports-ttrs 2/3 https://www.austrac.gov.au/business/core-guidance/reporting/reporting-transactions-10000-and-over-threshold-transaction-reports-ttrs 3/3"}, {"chunk_id": "6dfe4e63b9fb3c74::3e7::30f5", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "https://www.austrac.gov.au/business/core-guidance/reporting/reporting-transactions-10000-and-over-threshold-transaction-reports-ttrs 1/3 Exemptions from TTR obligations You don't have to submit a TTR if the designated service involving a threshold\ntransaction is provided: e ator through your permanent establishment in a foreign country e by an authorised deposit-taking institution (ADI) to a customer that is also an ADI e by the Reserve Bank of Australia to a customer that holds an exchange settlement\naccount (ESA) (that is, an account held at the Reserve Bank for settlement of\nobligations between ESA holders) e by an ESA holder to a customer that holds an exchange settlement account. Additionally, if you hold an Australian Financial Services Licence (AFSL) and only\narrange for a person to receive a designated service rather than providing it yourself,\nyou do not have to submit a TTR. Related pages How to submit a threshold transaction report (TTR)\nReporting multiple cash transactions"}], "rationale": "The AML/CTF Act Part 3 Division 3 (operationalised by AML/CTF Rules Chapter 19) imposes a Threshold Transaction Report obligation for cash transactions of A$10,000 or more, establishing a fixed numerical threshold. The same Act contains structuring offences (sections 142–143) that criminalise designing a transaction or pattern of transactions to fall below the TTR threshold. This is the textbook recurring_friction pair: the threshold itself creates the attractor for structuring behaviour, and the structuring offence exists *because of* the threshold. There is no compliant alternative design — the threshold is the regulatory device — but the cost of having chosen it persists indefinitely: reporting entities must continually monitor transaction patterns for structuring indicators, and AUSTRAC must continually invest in detection and enforcement. The friction is structural to the regime's design rather than a transitional artefact.", "compliant_paths": ["Maintain transaction monitoring systems calibrated for sub-threshold patterns; train staff to recognise and SMR-report structuring.", "Apply documented TTR exemptions (per AUSTRAC guidance) for genuinely exempt designated services."], "out_of_scope_assumptions": ["Recurring_friction is being labelled here as a property of the regime, not a violation by any individual entity."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:07:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:dbe4386f6c9248ff5409f7fa", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::5e6::a0b1", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "Initial views from consultation paper\n• Consultation paper focussed on • Stakeholders noted the complexity\nmarket licensing, custody and token of introducing new regulation\nmapping\n• Most stakeholders agreed that\n• Divergent views among many issues there is a need for custody\nregulation\n• Most agree that self-regulation is\nnot appropriate - Hard to implement detailed standards\nas each custodian operates differently\n• Differing views about creating\n- Capital requirements, insurance and\nbespoke regime or using the Corps\nliability for loss needs to be quite\nAct\nspecific\n- Sophisticated or larger stakeholders\n- No meaningful support for a domestic\nprefer more rigorous regulation (Corps\nlocation requirement. Act). Key terms and concepts\n• Blockchain • Crypto assets\n- A digital ledger comprised of - A useful blanket term that covers on-\nunchangeable, digitally recorded data chain assets: cryptocurrencies, NFTs,\nin packages called blocks. and other, still emerging, products.\n- Each block is 'chained' to the next\nblock using a cryptographic signature.\n• Web3 / Web 3.0\n- Ethereum is a public blockchain, open\n- Web3, or Web 3.0, are terms used\nto the world; its digital ledger is\nsynonymously with \"the decentralized\ndistributed, or synced, between many\nweb\" and are often used to refer,\nnodes; these nodes arrive at\nbroadly, to the blockchain and\nconsensus regarding whether a\ndecentralized technology ecosystems\ntransaction is valid before encrypting a\nas a whole.\nnumber of transactions into a block"}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "rationale": "The evidence from Regime A (AU_CORPS_ACT) focuses on the interaction of the Corporations Act with the Australian Charities and Not-for-profits Commission Act and discusses market licensing, custody, and token regulation in a consultation context (chunk_id d75262e404517e0c::5e6::a0b1). The evidence from Regime B (INT_BASEL_CRYPTO) defines bank exposures for capital requirements, focusing on financial institutions and prudential standards (chunk_id 32afd37cade34f84::3a4::1a5b). The obligations described in the Basel crypto framework relate to capital adequacy for banks, whereas the Corporations Act evidence discusses corporate governance and market licensing. There is no specific obligation in the Basel crypto framework that pushes against a specific obligation in the Corporations Act; they regulate different domains (banking capital vs. corporate governance/licensing)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:28a86bd05152758611902c39", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}], "rationale": "EU_AMLA (EU's Anti-Money Laundering Authority under AMLD6 — comprehensive AML/CFT framework) and INT_FATF_VASP (FATF VASP guidance — international AML/CFT standards for VAs and VASPs). EU's AMLA framework explicitly implements FATF AML standards including R16 (via TFR) and VASP-related obligations. Aligned by design."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:5738c4ded3c6d56355c22ce1", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::284::b4a8", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 38, "passage": "94. The FATF Standards, including the definitions of virtual assets and VASPs, represent\na minimum standard for countries to introduce. In line with the RBA, countries may\nchoose to extend their AML/CFT regimes to include other digital assets and entities,\nbeyond the FATF definition of virtual asset and VASP. Such a determination should\nbe made on the basis of a ML/TF risk assessment, with consideration of the\nchallenges associated with regulatory divergence.\n\nUPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS  37\nPART THREE:\nAPPLICATION OF FATF STANDARDS TO COUNTRIES AND\nCOMPETENT AUTHORITIES"}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}, {"chunk_id": "018117ef1e757630::4b5::9ef5", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Guidelines\n• MAS' surveillance efforts are • Existing VASPs operating in\nfocused on: (a) detecting and Singapore were required to notify\nLicensing\ndeterring unlicensed DPT activities MAS and submit licence\nSurveillance and\nin Singapore; and (b) leveraging applications by 28 Jul 2020.\ndata and blockchain analytics to Supervision\nidentify higher risk entities. • Applicants expected to\ndemonstrate understanding and\nability to mitigate ML/TF risks. Slide 5 (III) AML/CFT requirements for DPT sector\nAML/CFT requirements for digital payment token (DPT) service in Singapore\n• AML/CFT requirements are set out in MAS Notice PSN02 (issued 5 Dec 2019) and Guidelines to PSN02 (issued on 16 Mar 2020). Amendments to the Payment Services Act were passed in Parliament in Jan 2021 to expand the scope of DPT services and\nfurther updates to Notice PSN02 and Guidelines are in train to apply AML/CFT requirements to the newly scoped-in DPT services.\n• Entities that (a) deal in DPT; (b) facilitate the exchange of DPT; (c) facilitate the transmission of DPT; (d) and/or provide custodian\nwallet services, will therefore be required to be licensed as DPT service providers, and comply with the AML/CFT requirements."}], "rationale": "INT_FATF_VASP (FATF VASP standards as a minimum international AML/CFT framework) and SG_PSA_DPT (Singapore's DPT licensee AML obligations under MAS PSN02). Singapore explicitly implements FATF VASP guidance through MAS's PSA framework; the B passages describe MAS surveillance and licensing of VASPs operating in Singapore consistent with FATF guidance. Reinforcing."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:51:54Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:3f53fd5a7c59cfcca04ea00d", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4024f4c4c1616cc::23d::700a", "source_doc": "AMLR_Regulation_EU_2024-1624.pdf", "page": 2, "passage": "(7) Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers\nof funds and certain crypto-assets and amending Directive (EU) 2015/849 (OJ L 150, 9.6.2023, p. 1).\n\n(8) Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing the Authority for\nAnti-Money Laundering and Countering the Financing of Terrorism and amending Regulations (EU) No 1093/2010, (EU)\nNo 1094/2010 and (EU) No 1095/2010 (OJ L, 2024/1620, 19.6.2024, http://data.europa.eu/eli/reg/2024/1620/oj)."}, {"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "rationale": "The EU AMLR TFR passages focus on anti-money laundering obligations, specifically the traceability of crypto-asset transfers and the definition of 'self-hosted addresses' (c4024f4c4c1616cc::23d::700a, c0300673081f7232::279::1918). The INT_BASEL_CRYPTO passages focus on prudential capital requirements and risk-weighting for bank exposures to financial institutions (32afd37cade34f84::3a4::1a5b). The obligations in Regime A (AML/CFT reporting and identification) do not impose a direct conflict with the obligations in Regime B (capital adequacy and risk weighting). The regimes regulate distinct aspects of financial activity—compliance and transparency versus solvency and risk management—and do not overlap in a way that creates a mutually exclusive obligation."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:19:28Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:4c3061245a0968bf096c46c5", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "Regime A (AU_APRA_CPS234) is a Prudential Practice Guide regarding Operational Risk Management and Information Security for APRA-regulated entities. Regime B (SG_PSA_DPT) is a MAS Notice regarding AML/CFT obligations for holders of payment service licences providing Digital Payment Token services. The obligations in Regime A relate to internal risk management frameworks and information security practices, while the obligations in Regime B relate to anti-money laundering and counter-terrorism financing compliance. The regimes regulate distinct domains of compliance—prudential risk management versus financial crime prevention—and do not impose conflicting obligations on the same specific activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:df60c84baea685ccdfb0718c", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "f7803fb0f472e356::41a::fb28", "source_doc": "Basel-II-Enhancements-RIS-May-2011.pdf", "page": 4, "passage": "The crisis has shown that collateralised debt obligations comprised of\nasset-backed securities (i.e. CDOs of ABS or so-called 'resecuritisations') are more\nhighly correlated with risk than are traditional securitisations. APRA reviewed its\nprudential standard for securitisation and assessed that the current requirements do not\ncapture the risks associated with these resecuritisation structures. The BCBS also formed the view that increased disclosure requirements should\nprovide timely, relevant, reliable and useful decision-making information that\npromotes institutional transparency. APRA also identified that its prudential\nrequirements for disclosure did not cover certain elements relating to an ADI's\nsecuritisation exposures. Therefore, based on APRA's experience as the prudential supervisor during the crisis\nand analysis of its prudential framework for ADIs, APRA believes that the\ndeficiencies that the Basel II enhancements are seeking to address exist in the\nAustralian prudential framework and present risks that require addressing."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "rationale": "AU_APRA_PRUDENTIAL (APRA's broader prudential framework — Basel-aligned standards) and INT_BASEL_GENERAL (Basel III framework). APRA implements Basel standards in Australia; the cited A passage is a Basel II Enhancements RIS document confirming the implementation relationship. Aligned by design."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:24:59Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:741d2dcc6be3e91392d3b69a", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::34a::74e3", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 11, "passage": "33. Article 109(1)(d) MiCA requires ESMA to establish a register of CASPs which must be\npublicly available on its website and be updated on a regular basis. Article 109(5) MiCA\nspecifies the information which the register must contain, including the name, legal form\nand legal entity identifier of the CASP and, where applicable, of the where applicable, of\nthe CASP's branches and the list of crypto-asset services provided by the CASP. To\nensure that an application for authorisation also contains all information required for the\nfuture ESMA public register of CASPs, ESMA proposes to include a few additional\ninformation requirements of limited extent to reflect the requirements of Article 109(5) of\nMiCA in the draft RTS on the application for authorisation as a CASP.\n\n4 Complaints-handling procedures of crypto-asset service\nproviders"}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "75b61beed88910f9::4ad::debc", "source_doc": "National_ML_TF_Risk_Assessment.pdf.coredownload.inline.pdf", "page": null, "passage": "The guidance contained in this document takes into consideration previous FATF work , which is still valid reference material. The general\nprinciples contained in this paper are also relevant when conducting risk assessments of a more\nfocussed scope, such as in assessments of a particular financial or DNFBP sector (for example, the\nsecurities sector) or of thematic issues (for example, the proceeds of corruption related ML). All of\nthese types of assessments (comprehensive, sectoral or thematic) carried out at the national level\nmay also form the basis for determining whether to apply enhanced or specific measures, simplified\nmeasures, or exemptions from AML/CFT requirements. Furthermore, while FATF\nRecommendation 1 does not create specific risk assessment obligations regarding the financing of\nproliferation of weapons of mass destruction, the general principles laid out in this guidance could\nalso be used in conducting a risk assessment for this area.\n3. The guidance in this document is not intended to explain how supervisors should assess risks\nin the context of risk-based supervision, although risk-based supervision will likely be informed by a\nnational-level risk assessment."}], "rationale": "The EU MiCA passages (c51ad46265cea4e5::147::6214, c51ad46265cea4e5::34a::74e3) regulate the licensing and registration of Crypto-Asset Service Providers (CASPs) within the EU. The FATF passages (fe52dd87e13dba41::261::59a4, 75b61beed88910f9::4ad::debc) provide general principles for assessing Money Laundering and Terrorist Financing (ML/TF) risks. While MiCA CASPs will be subject to FATF AML/CFT standards, the provided passages do not describe a specific regulatory obligation in MiCA that conflicts with a specific obligation in FATF. Instead, they address distinct regulatory domains: MiCA focuses on the operational authorization of crypto firms, whereas FATF focuses on the general risk assessment framework for AML/CFT compliance."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:11:13Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b75f3d605902d67789bb19b7", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::5c7::68f5", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 10, "passage": "You should obtain the sum of the absolute values of\nexempt supplies from each category to report in your GST return. Category of exempt supplies Exchange gain (loss) for digital\nfor the accounting period from payment tokens\nJan 2020 to Mar 2020\nExchange gain (loss) for digital (200)\npayment tokens Exchange gain (loss) for foreign 400\ncurrency\nInterest received from deposit with 300\nbanks\nValue of exempt supplies |(200)| + 400 + 300\n= $900\nQ9 Can I report the value of supply of digital payment tokens issued during\nmy ICO based on the proceeds received, and then report the value of\nsupply for subsequent transactions based on realised gain or loss? A9 Yes, you may report the proceeds received as the value of supply for ICO\ntransactions. For subsequent exchanges of the tokens for fiat currency or\nother digital payment tokens, you may choose to report the realised gain or\nloss. This is allowed as long as you apply the method chosen consistently.\n14 Contact information\n10.1 For enquiries on this e-Tax Guide, please contact the Goods and Services\nTax Division at www.iras.gov.sg (select \"Contact Us\")\n15 Updates and Amendments\nDate of\nAmendments made\namendment\n1 3 Aug 2022 • Editorial changes.\n• Amended paragraphs 3.6 and 3.8 to reflect the\ndefinition in Income Tax e-Tax Guide on digital\npayment tokens.\n• Added paragraph 5.11 to clarify that if a digital\npayment token is listed on an exchange, IRAS will\nregard the token as suitable for use as a medium\nof exchange."}, {"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}], "rationale": "The EU MICA Title IV EMT regime regulates the disclosure and liability obligations for issuers of e-money tokens and asset-referenced tokens (e.g., Article 51 and 52 regarding white paper notifications and liability for misleading information). In contrast, the SG IRAS Tax regime addresses the Goods and Services Tax (GST) treatment of digital payment tokens, specifically exempting their supply from GST and outlining record-keeping requirements for businesses trading in them. The obligations in the EU regime relate to financial disclosure and issuer liability, while the obligations in the SG regime relate to tax treatment and record-keeping for GST purposes. These are distinct regulatory domains with no apparent overlap or conflict regarding the specific obligations described in the provided passages."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:37:05Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:8a69ec512224891ec0e8732e", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The evidence from Regime A (AU_ASIC_CRYPTO) focuses on the interpretation of the Corporations Act 2001 regarding crypto-assets as financial products and the licensing requirements for financial services (e.g., AFS licences). The evidence from Regime B (SG_FOUNDATIONAL_LEGISLATION) discusses MAS's enforcement actions against ICO issuers and exchanges, as well as its intention to expand legislation to align with FATF standards. The obligations in Regime A relate to the definition of financial products and licensing under Australian law, while the obligations in Regime B relate to MAS's regulatory scope and enforcement in Singapore. These are distinct regulatory domains with no specific obligation in one regime pushing against a specific obligation in the other. Therefore, the regimes are in non_conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:83b21c1155638d9f1e26bbeb", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "rationale": "AU_APRA_CPS234 (APRA Information Security prudential standard) and INT_BASEL_CRYPTO (Basel d424 prudential treatment of crypto exposures — bank capital calculation). Both touch on prudential / risk frameworks for financial entities but address materially different concerns — APRA infosec is about cybersecurity controls; Basel crypto is about capital requirements for crypto exposures. Distinct mechanisms; no direct conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:28:09Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f07604017def3afadb9d29a1", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::5e6::a0b1", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "Initial views from consultation paper\n• Consultation paper focussed on • Stakeholders noted the complexity\nmarket licensing, custody and token of introducing new regulation\nmapping\n• Most stakeholders agreed that\n• Divergent views among many issues there is a need for custody\nregulation\n• Most agree that self-regulation is\nnot appropriate - Hard to implement detailed standards\nas each custodian operates differently\n• Differing views about creating\n- Capital requirements, insurance and\nbespoke regime or using the Corps\nliability for loss needs to be quite\nAct\nspecific\n- Sophisticated or larger stakeholders\n- No meaningful support for a domestic\nprefer more rigorous regulation (Corps\nlocation requirement. Act). Key terms and concepts\n• Blockchain • Crypto assets\n- A digital ledger comprised of - A useful blanket term that covers on-\nunchangeable, digitally recorded data chain assets: cryptocurrencies, NFTs,\nin packages called blocks. and other, still emerging, products.\n- Each block is 'chained' to the next\nblock using a cryptographic signature.\n• Web3 / Web 3.0\n- Ethereum is a public blockchain, open\n- Web3, or Web 3.0, are terms used\nto the world; its digital ledger is\nsynonymously with \"the decentralized\ndistributed, or synced, between many\nweb\" and are often used to refer,\nnodes; these nodes arrive at\nbroadly, to the blockchain and\nconsensus regarding whether a\ndecentralized technology ecosystems\ntransaction is valid before encrypting a\nas a whole.\nnumber of transactions into a block"}], "evidence_b": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "rationale": "The evidence for Regime A (AU_CORPS_ACT) focuses on the interaction with the Australian Charities and Not-for-profits Commission Act and general provisions regarding corporate governance, civil liability, and token custody regulation (chunk_id d75262e404517e0c::5e6::a0b1). The evidence for Regime B (EU_AMLR_TFR) concerns the European Union's Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) framework, specifically extending obligations to crypto-asset service providers and the traceability of crypto-asset transfers (chunk_id c0300673081f7232::279::1918). The obligations in Regime B relate to the reporting and monitoring of financial transactions for AML/CFT purposes, whereas the obligations in Regime A relate to corporate governance and the regulation of crypto-asset custody. These are distinct regulatory domains that do not impose conflicting obligations on the same specific activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:47:50Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:5eb648fc45b02d520dc8b164", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4a92930a8caf822::380::0a18", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 12, "passage": "Part 1 Preliminary\nSection 1-4\n(a) in relation to registration or proposed registration of a person under Part 6\nof the Act as a remittance network provider-registrable remittance\nnetwork services; or\n(b) in relation to registration or proposed registration of a person under Part 6\nof the Act as an independent remittance dealer or a remittance affiliate of a\nregistered remittance network provider-registrable remittance services; or\n(c) in relation to registration or proposed registration of a person under Part 6A\nof the Act as a virtual asset service provider-registrable virtual asset\nservices.\nrelated body corporate has the same meaning as in the Corporations Act 2001.\nsuper-agent has the meaning given by subsection 4-13(2).\ntracing information, in relation to a transfer of value, means information that\nsatisfies both of the following:\n(a) the information:\n(i) for a transfer from an"}, {"chunk_id": "c4a92930a8caf822::57d::3f76", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 28, "passage": "Part 4-Registration\nDivision 1-Management of the Remittance Sector Register and the\nVirtual Asset Service Provider Register\n4-1 Correction of entries\n(1) This section is made for the purposes of paragraphs 75(4)(a) and 76B(4)(a) of the\nAct. (2) If the AUSTRAC CEO reasonably believes that there is an error in, or omission\nfrom, an entry in the Remittance Sector Register or the Virtual Asset Service\nProvider Register, the AUSTRAC CEO may correct the error or omission. (3) As soon as reasonably practicable after making a correction of an entry under\nthis section, the AUSTRAC CEO must give notice of the correction to:\n(a) the person whose registration the entry relates to; and\n(b) if the registration is of a person as a remittance affiliate of a registered\nremittance network provider-the provider.\n4-2 Publication of register information\n(1) For the purposes of subsections 75(4) and 76B(4) of the Act, the AUSTRAC\nCEO must publish the following on AUSTRAC's website:\n(a) the details mentioned in paragraphs 75A(1)(a), (b), (c) and (f) of the Act on\nthe Remittance Sector Register;\n(b) the details mentioned in paragraphs 76C(a) and (d) of the Act on the\nVirtual Asset Service Provider Register;\n(c) information mentioned in section 4-24 of this instrument (register entry in\nrelation to suspension of registration) on the Remittance Sector Register\nand the Virtual Asset Service Provider Register."}, {"chunk_id": "c4a92930a8caf822::37f::8a4f", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 98, "passage": "mentioned in item 2 (ii) tracing information\ndo not apply\n4 the transfer of value is a merchant payment card number of the card the payer used in\nrelation to the merchant payment\n5 the transfer of value is a refund of a card number of the card the payer used in\nmerchant payment relation to the merchant payment that is\nrefunded\n6 the instruction for the transfer of value is card number of the card the payer used in\ngiven by the use of an ATM relation to the withdrawal\n7 (a) the value being transferred is money; and tracing information\n(b) the money is in a foreign country and, as\na result of the provision of an\ninternational value transfer service, the\nmoney will be in Australia; and\n(c) the beneficiary institution receives the\ntransfer message for the transfer of value\nthrough BECS\n8 the value is transferred from a self-hosted (a) payer information; and\nvirtual asset wallet (b) the"}, {"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "ffa7a3de1e0fc7f0::7bc::38ba", "source_doc": "d426.pdf", "page": 7, "passage": "1. General remarks\nThe Basel III framework is a central element of the Basel Committee's response to the global financial crisis.\nIt addresses a number of shortcomings with the pre-crisis regulatory framework and provides a regulatory\nfoundation for a resilient banking system that supports the real economy.\nThe Committee's finalisation of the Basel III reforms1 complements the improvements made to\nthe global regulatory framework from the initial phase of the Basel III framework. The revisions seek to\nrestore credibility in the calculation of risk-weighted assets (RWA) and therefore also capital ratios by:\n• enhancing the robustness and risk sensitivity of the standardised approaches for credit risk and\noperational risk, which will help facilitate the comparability of banks' capital ratios;\n• constraining the use of internally modelled approaches, by placing limits on certain inputs used\nto calculate RWA under the internal ratings-based (IRB) approach for credit risk and by removing\nthe use of the modelled approach for operational risk;\n• finalising the leverage ratio, which now includes a buffer to further limit the leverage of global\nsystemically important banks (G-SIBs); and\n• replacing the existing Basel I-based floor with a robust aggregate 72.5% output floor based on\nthe Committee's revised standardised approaches.\nIn order to analyse the impact of the revised standards, the Committee conducted an ad hoc\nBasel III monitoring exercise with the data collection starting in April 2016, in addition to its regular Basel III\nmonitoring exercise2 and the data collection exercise from regulatory reporting systems. This report\nsummarises the aggregate cumulative quantitative impact study results using data jointly from all three\nexercises. The Committee believes that the information contained in the report will provide relevant\nstakeholders with a useful benchmark for analysis as well as provide an estimated impact of the recently\nagreed upon reforms."}, {"chunk_id": "32afd37cade34f84::34e::4d5c", "source_doc": "d424.pdf", "page": 84, "passage": "141. Section G discusses the method by which the difference between provisions (eg specific\nprovisions, portfolio-specific general provisions such as country risk provisions or general provisions) and\nexpected losses may be included in or must be deducted from regulatory capital, as outlined in the\ndefinition of capital section of the Basel III framework (June 2011).\n\n1. Calculation of expected losses\n\n142. A bank must sum the EL amount (defined as EL multiplied by EAD) associated with its exposures\nto which the IRB approach is applied (excluding the EL amount associated with securitisation exposures)\nto obtain a total EL amount. The treatment of EL for securitisation exposures is described in paragraph 37\nof the securitisation framework.\n(i) Expected loss for exposures other than exposures subject to the supervisory slotting\ncriteria"}, {"chunk_id": "32afd37cade34f84::25d::6825", "source_doc": "d424.pdf", "page": 85, "passage": "150. At national supervisory discretion, banks using both the standardised and IRB approaches may\nrely on their internal methods for allocating general provisions for recognition in capital under either the\nstandardised or IRB approach, subject to the following conditions. Where the internal allocation method\nBasel III: Finalising post-crisis reforms 81\n\nis made available, the national supervisor will establish the standards surrounding their use. Banks will\nneed to obtain prior approval from their supervisors to use an internal allocation method for this purpose.\n\n3. Treatment of EL and provisions"}, {"chunk_id": "4b8050428e00a093::253::d1c3", "source_doc": "d457.pdf", "page": 113, "passage": "40.32 The derivatives should be converted into positions in the relevant underlying and become subject\nto specific and general market risk charges as described above. In order to calculate the standard\nformula described above, the amounts reported should be the market value of the principal\namount of the underlying or of the notional underlying resulting from the prudent valuation\nguidance set out in paragraphs 690 to 701 in Basel II.[8]\nFootnote\n[8] For instruments where the apparent notional amount differs from the effective notional\namount, banks must use the effective notional amount."}], "rationale": "The regimes regulate distinct domains. Regime A (AU_TRAVEL_RULE) pertains to Australian financial services regulation, specifically the registration of remittance network providers and virtual asset service providers, and the implementation of the FATF 'Travel Rule' for digital currency transactions. Regime B (INT_BASEL_GENERAL) pertains to international banking regulation, specifically the Basel III framework for capital adequacy, leverage ratios, and risk-weighted assets. The cited passages for Regime A discuss AML/CTF obligations and the Travel Rule, while the cited passages for Regime B discuss accounting frameworks, leverage ratios, and expected losses. There is no overlap of obligations between the two regimes."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:16:58Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:09ad701a2af29e974de01819", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The AU_FEDREG_AML passages describe the scope and obligations of Australia's AML/CTF regime, specifically regarding reporting entities, customer identification, and suspicious transaction reporting (chunk cf7cefacba3f94bc::49a::f39e). The MAS_TRM passages discuss the application of the TRM Guidelines to licensees, emphasizing that these guidelines are principles-based statements of industry best practices rather than prescriptive obligations (chunk 20d526d712753652::401::f956). The regimes regulate different aspects of financial services compliance—Australia's AML/CTF obligations versus Singapore's TRM principles-based guidelines—and do not impose conflicting requirements on the same specific obligation."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:08faf52f5faf4bb2ace57ded", "label": "conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "conflict_type": "recurring_friction", "severity": "medium", "evidence_a": [{"chunk_id": "a0d157539d5c8040::2fc::beb4", "source_doc": "FinalReport_Market_Abuse_Guidelines_MiCA.pdf", "page": 6, "passage": "2 Background and Legal Basis\nArticle 92 (3) of MiCA:\nIn order to ensure consistency of supervisory practices under this Article, ESMA shall by 30\nJune 2025 issue guidelines in accordance with Article 16 of Regulation (EU) No 1095/2010 on\nsupervisory practices among the competent authorities to prevent and detect market abuse, if\nnot already covered by the regulatory technical standards referred to in paragraph 2.\n\n1. To promote confidence in markets in crypto-assets and ensure their integrity, Title VI of\nMiCA lays down rules on prevention and prohibition of market abuse involving crypto\nassets.\n\n2. Article 92(1) of MiCA requires any PPAET in crypto-assets to have in place effective\narrangements, systems and procedures to prevent and detect market abuse."}, {"chunk_id": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "INT_BASEL_CRYPTO (Basel d424 — prudential capital treatment of bank crypto-asset exposures, with high risk weights for unbacked crypto and conditional treatments for tokenised traditional assets) and EU_MICA (EU framework allowing bank participation in the crypto market as CASPs / EMT issuers). For bank-affiliated MiCA participants, every crypto exposure generates ongoing Basel capital charges; every operational decision is shaped by the interaction between MiCA's authorisation perimeter and Basel's capital framework. The friction is structural to the design — banks bear the cost of running crypto activities under a non-crypto-native capital framework.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:26Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:6cc7afc649b0c75b596d845f", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::3c5::d461", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 33, "passage": "80. Despite the many and frequently changing marketing terms and innovative\nbusiness models developed in this sector, the FATF envisions very few VA\narrangements without VASPs involved at some stage if countries apply the\ndefinition correctly. Countries should take particular care to assess any claims that\nbusinesses may make as to models of decentralization or distributed services, and\nconduct their own assessment of the business model in line with its risk and their\nability to mitigate these risks.\n\n81. As previously stated, the FATF Standards are technology neutral. As such, the FATF\ndoes not seek to regulate the technology that underlies VAs or VASP activities.\nRather the FATF seeks to regulate natural or legal persons behind such technologies\n\n32  UPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS\nthat conduct as a business the aforementioned VASP activities on behalf of another\nnatural or legal person."}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}, {"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "INT_FATF_VASP (regime A) and SG_FSMA_DTSP (regime B) — FATF sets minimum standards for VASP regulation; SG's FSM Act DTSP licensing is Singapore's specific implementation of those standards. The B passages describe MAS issuing the consultation paper and licensing requirements for digital token service providers under the FSM Act, which is the local instantiation of the FATF Recommendations. Reinforcing relationship."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:12:33Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:c11d60c33376e10aaddf83a0", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "SG_MAS_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}], "evidence_b": [{"chunk_id": "a82833dc0f7ca903::5f1::735d", "source_doc": "Outsourcing_Guidelines_2018.pdf", "page": 25, "passage": "5.10.2 Material outsourcing arrangements with service providers located outside Singapore\nshould be conducted in a manner so as not to hinder MAS' efforts to supervise the Singapore\nbusiness activities of the institution (i.e., from its books, accounts and documents) in a timely\nmanner, in particular:\n(a) An institution should, in principle, enter into outsourcing arrangements only\nwith service providers operating in jurisdictions that generally uphold\nconfidentiality clauses and agreements.\n\n(b) An institution should not enter into outsourcing arrangements with service\nproviders in jurisdictions where prompt access to information by MAS or\nagents appointed by MAS to act on its behalf, at the service provider, may\nbe impeded by legal or administrative restrictions. An institution must at\nleast commit to retrieve information readily from the service provider\nshould MAS request for such information. The institution should confirm in\nwriting to MAS, that the institution has provided, in its outsourcing\nagreements, for MAS to have the rights of inspecting the service provider,\nas well as the rights of access to the institution and service provider's\ninformation, reports and findings related to the outsourcing arrangement,\nas set out in paragraph 5.9.\n(c) An institution should notify MAS if any overseas authority were to seek\naccess to its customer information or if a situation were to arise where the\nrights of access of the institution and MAS set out in paragraph 5.9, have\nbeen restricted or denied."}], "rationale": "The AU Travel Rule passage (chunk cf7cefacba3f94bc::383::7d9d) discusses the *absence* of the Travel Rule for digital currency exchanges in Australia and the *consultation* on extending it. The SG MAS Outsourcing passage (chunk a82833dc0f7ca903::5f1::735d) outlines general supervisory expectations for material outsourcing arrangements with service providers located outside Singapore, specifically regarding timely access to information. The two regimes regulate distinct aspects of the digital asset ecosystem: one addresses the specific regulatory status of the Travel Rule in Australia, while the other addresses general supervisory expectations for outsourcing in Singapore. There is no specific obligation in the SG MAS Outsourcing guidelines that conflicts with the specific obligation or lack thereof in the AU Travel Rule regarding the Travel Rule's implementation."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:50:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:0019cbbfdd6cad785d47474d", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "evidence_b": [{"chunk_id": "3d9b3d4849297e91::3c6::7b85", "source_doc": "2025_CP_Prudential_Treatment_Cryptoassets.pdf", "page": null, "passage": "Preface | 4\n1.6 MAS invites comments from banks and other interested parties. Please refer to Annex A for the list of\nquestions.\n1.7 Please note that all submissions received will be published and attributed to the respective respondent\nunless they expressly request MAS not to do so. As such, if respondents would like\n(a) their whole submission or part of it (but not their identity), or\n(b) their identity along with their whole submission,\nto be kept confidential, please expressly state so in the submission to MAS. MAS will only publish\nnon-anonymous submissions. In addition, MAS reserves the right not to publish any submission\nreceived where MAS considers it not in the public interest to do so, such as where the submission\nappears to be libelous or offensive.\n1.8 Please submit written comments via email to prudential_policy_dept@mas.gov.sg using the suggested\ntemplate by 28 April 2025. Prudential Treatment & Disclosures of Cryptoasset Exposures | 5\n2."}, {"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "The EU DAC8 regime focuses on tax transparency and the automatic exchange of information regarding crypto-asset users (chunk_ids c0300673081f7232::320::7b46, c0300673081f7232::498::163c). In contrast, the SG MAS Prudential Crypto regime addresses the prudential treatment, capital requirements, and operational standards for cryptoasset exposures and stablecoins (chunk_ids 3d9b3d4849297e91::3c6::7b85, 7c04f2a0bd85290a::449::02f2). The obligations in DAC8 relate to reporting to tax authorities, while the obligations in MAS relate to financial stability and risk management. These are distinct regulatory domains that do not impose conflicting obligations on the same entity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:7c7e746cedace19bd8814a78", "label": "conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "conflict_type": "recurring_friction", "severity": "medium", "evidence_a": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "evidence_b": [{"chunk_id": "e3809bb1f352508e::38a::ddd7", "source_doc": "Guidelines_Reverse_Solicitation_MiCA.pdf", "page": 14, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}, {"chunk_id": "25cbbd878a1b21d3::38a::ddd7", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 47, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}], "rationale": "EU_DAC8 (EU crypto-asset tax reporting directive) and EU_MICA (broad EU crypto-asset regulation). Recurring friction: MiCA-regulated activities generate DAC8 reporting obligations on every relevant transaction; the combined ongoing cost is a function of design choice rather than a one-time issue.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:35Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:36:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:0d3bbe321758b0cb1720dad6", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "The AU_TREASURY_DAP passages discuss the Australian government's regulatory reform agenda for crypto assets, specifically 'token mapping' and licensing frameworks for financial services (chunk_ids d75262e404517e0c::47b::7c9f, e6bb47e92e88e16c::37a::29f6). In contrast, the SG_PDPA passages regulate the collection, use, and disclosure of personal data under Singapore's Personal Data Protection Act, focusing on consent requirements and data handling (chunk_id 0e996ae99839f19e::37b::85a8). The obligations in the Australian crypto asset reform do not impose specific data protection requirements that conflict with the Singapore PDPA's consent and data handling rules. Therefore, the regimes regulate different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:22:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:6334d72fa7205584431c7af0", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::34a::74e3", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 11, "passage": "33. Article 109(1)(d) MiCA requires ESMA to establish a register of CASPs which must be\npublicly available on its website and be updated on a regular basis. Article 109(5) MiCA\nspecifies the information which the register must contain, including the name, legal form\nand legal entity identifier of the CASP and, where applicable, of the where applicable, of\nthe CASP's branches and the list of crypto-asset services provided by the CASP. To\nensure that an application for authorisation also contains all information required for the\nfuture ESMA public register of CASPs, ESMA proposes to include a few additional\ninformation requirements of limited extent to reflect the requirements of Article 109(5) of\nMiCA in the draft RTS on the application for authorisation as a CASP.\n\n4 Complaints-handling procedures of crypto-asset service\nproviders"}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}, {"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "rationale": "The EU MiCA passages focus on the licensing requirements, application procedures, and public register obligations for Crypto-Asset Service Providers (CASPs) under Article 62 and 109. The FATF passages focus on global AML/CFT standards, specifically regarding Digital Identity and Virtual Assets. While MiCA requires CASPs to be licensed and FATF provides guidance on customer due diligence and red flags for virtual assets, the specific obligations cited in the passages do not create a direct legal conflict. MiCA establishes the licensing framework, while FATF provides international standards for AML/CFT compliance that generally reinforce the need for regulated entities to adhere to due diligence requirements. The regimes regulate different aspects of the same activity (licensing vs. AML/CFT standards) and do not appear to push against one another in a way that creates an unresolved conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:a3b70f5e2cee6a5225ad1b41", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "MAS AML/CFT Notices"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::4d0::eb51", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 28, "passage": "Authorisation as a crypto-asset service provider pursuant to Article 59 is not required for providing custody and\nadministration of crypto-assets on behalf of clients or for providing transfer services for crypto-assets in relation to\ncrypto-assets whose offers to the public are exempt pursuant to paragraph 3 of this Article, unless:\n(a) there exists another offer to the public of the same crypto-asset and that offer does not benefit from the exemption;\nor\n(b) the crypto-asset offered is admitted to a trading platform.\n6. Where the offer to the public of the crypto-asset other than an asset-referenced token or e-money token concerns\na utility token providing access to goods and services that do not yet exist or are not yet in operation, the duration of\nthe offer to the public as described in the crypto-asset white paper shall not exceed 12 months from the date of\npublication of the crypto-asset white paper.\n7. Any subsequent offer to the public of the crypto-asset other than an asset-referenced token or e-money token shall\nbe deemed a separate offer to the public to which the requirements of paragraph 1 apply, without prejudice to the\npossible application of paragraph 2 or 3 to the subsequent offer to the public."}, {"chunk_id": "491a2f0014d56ffb::5dc::7b39", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 84, "passage": "Article 65\nCross-border provision of crypto-asset services\n1.\nA crypto-asset service provider that intends to provide crypto-asset services in more than one Member State shall\nsubmit the following information to the competent authority of the home Member State:\n(a) a list of the Member States in which the crypto-asset service provider intends to provide crypto-asset services;\n(b) the crypto-asset services that the crypto-asset service provider intends to provide on a cross-border basis;\n(c) the starting date of the intended provision of the crypto-asset services;\n(d) a list of all other activities provided by the crypto-asset service provider not covered by this Regulation.\n2.\nThe competent authority of the home Member State shall, within 10 working days of receipt of the information\nreferred to in paragraph 1, communicate that information to the single points of contact of the host Member States, to\nESMA and to EBA.\n3.\nThe competent authority of the Member State that granted authorisation shall inform the crypto-asset service\nprovider concerned of the communication referred to in paragraph 2 without delay.\n4.\nThe crypto-asset service provider may begin to provide crypto-asset services in a Member State other than its\nhome Member State from the date of receipt of the communication referred to in paragraph 3 or at the latest from the\n15th calendar day after having submitted the information referred to in paragraph 1.\nCHAPTER 2\nObligations for all crypto-asset service providers"}], "evidence_b": [{"chunk_id": "39886a6842407c92::319::727a", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 31, "passage": "11.8 All wire transfer originator and beneficiary information collected by the ordering institution\nshall be documented.\n\n11.9 Where the ordering institution is unable to comply with the requirements in paragraphs\n11.3 to 11.8, it shall not execute the wire transfer.\nResponsibility of the Beneficiary Institution\n\n11.10 A bank that is a beneficiary institution shall take reasonable measures, including post-\nevent monitoring or real-time monitoring where feasible, to identify cross-border wire\ntransfers that lack the required wire transfer originator or required wire transfer beneficiary\ninformation.\n\n11.11 For cross-border wire transfers, a beneficiary institution shall identify and verify the\nidentity of the wire transfer beneficiary if the identity has not been previously verified."}, {"chunk_id": "f5d3fd73849ee27c::3b9::4f9f", "source_doc": "MAS_Notice_PSN01_2024-04-02.pdf", "page": 36, "passage": "15.10 All wire transfer originator and beneficiary information collected by the ordering institution\nshall be documented.\n\n15.11 Where the ordering institution is unable to comply with the requirements in paragraphs\n15.3 to 15.10, it shall not execute or arrange for the wire transfer.\n\nResponsibility of the Beneficiary Institution\n\n15.12 A payment service provider that is a beneficiary institution shall take reasonable\nmeasures, including post-event monitoring or real-time monitoring where feasible, to\nidentify cross-border wire transfers that lack the required wire transfer originator or\nrequired wire transfer beneficiary information.\n\n15.13 For cross-border wire transfers where the beneficiary institution pays out funds in cash or\ncash equivalent to the wire transfer beneficiary in Singapore, a beneficiary institution shall\nidentify and verify the identity of the wire transfer beneficiary if the identity has not been\npreviously verified."}], "rationale": "MiCA is an EU authorisation and conduct regime for issuers and CASPs operating in the EU; the MAS AML/CFT Notices are Singapore-law obligations on MAS-regulated FIs (banks, merchant banks, finance companies, PSPs). They operate on different regulated populations in different jurisdictions and on different subject matters: market authorisation/conduct vs AML/CFT operational controls. A firm that is both a MiCA-authorised CASP and a MAS-regulated FI must comply with both, but there is no obligation in one that pushes against any obligation in the other. A labeller might think they conflict because both touch crypto-finance, but on inspection the domains are disjoint at the obligation level.", "would_conflict_if": ["MiCA contained a provision purporting to authorise conduct that MAS AML/CFT Notices would prohibit for a Singapore-regulated entity (it does not)."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:21:06Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:a3b70f5e2cee6a5225ad1b41", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}], "evidence_b": [{"chunk_id": "018117ef1e757630::428::d321", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Strengthening AML/CFT Controls of\nDigital Payment Token Service Providers\nMarch 2021 Introduction\nThis infographic sets out recent international developments and MAS' supervisory expectations on\nAML/CFT controls for the Digital Payment Token (DPT) sector.\n• This infographic is intended to raise industry awareness to the money laundering and terrorism financing (ML/TF)\nrisks in the DPT sector, and provide additional supervisory information to help DPT service providers implement\neffective policies, procedures and controls to deal with the ML/TF risks.\n• In particular, this infographic focuses on:\nI) Financial Action Task Force (FATF) Standards and recent developments;\nII) ML/TF Risks in DPT sector; and\nIII) Overview of MAS' AML/CFT requirements and expectations for the DPT sector - including key AML/CFT\nconsiderations relating to new DPT products, enhanced customer due diligence (ECDD) and value transfer.\n• The infographic supplements existing AML/CFT requirements, and should be read in conjunction with the Notice\nPS-N02 and accompanying Guidelines."}], "rationale": "The EU_MICA passages describe the regulatory framework for crypto-asset service providers, including the provision of advice on crypto-assets and the issuance of guidelines on competence (chunk_id f9082873c5d9ba9d::302::bbe0). The SG_AML passages focus on AML/CFT controls for the Digital Payment Token (DPT) sector, specifically supervisory expectations and requirements for DPT service providers (chunk_id 018117ef1e757630::428::d321). While both regimes regulate the crypto-asset sector, they address distinct regulatory domains: MiCA establishes the licensing and conduct standards for crypto-asset service providers, whereas the Singapore AML/CFT guidelines focus on the prevention of money laundering and terrorism financing for DPT service providers. There is no specific obligation in MiCA that directly conflicts with the AML/CFT obligations in the Singapore guidelines; rather, they operate in complementary domains to ensure the integrity of the crypto-asset market."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:41:05Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:e1e8e7ead39a953e80fb6974", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e3809bb1f352508e::38a::ddd7", "source_doc": "Guidelines_Reverse_Solicitation_MiCA.pdf", "page": 14, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}, {"chunk_id": "a0d157539d5c8040::2fc::beb4", "source_doc": "FinalReport_Market_Abuse_Guidelines_MiCA.pdf", "page": 6, "passage": "2 Background and Legal Basis\nArticle 92 (3) of MiCA:\nIn order to ensure consistency of supervisory practices under this Article, ESMA shall by 30\nJune 2025 issue guidelines in accordance with Article 16 of Regulation (EU) No 1095/2010 on\nsupervisory practices among the competent authorities to prevent and detect market abuse, if\nnot already covered by the regulatory technical standards referred to in paragraph 2.\n\n1. To promote confidence in markets in crypto-assets and ensure their integrity, Title VI of\nMiCA lays down rules on prevention and prohibition of market abuse involving crypto\nassets.\n\n2. Article 92(1) of MiCA requires any PPAET in crypto-assets to have in place effective\narrangements, systems and procedures to prevent and detect market abuse."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "ffa7a3de1e0fc7f0::7bc::38ba", "source_doc": "d426.pdf", "page": 7, "passage": "1. General remarks\nThe Basel III framework is a central element of the Basel Committee's response to the global financial crisis.\nIt addresses a number of shortcomings with the pre-crisis regulatory framework and provides a regulatory\nfoundation for a resilient banking system that supports the real economy.\nThe Committee's finalisation of the Basel III reforms1 complements the improvements made to\nthe global regulatory framework from the initial phase of the Basel III framework. The revisions seek to\nrestore credibility in the calculation of risk-weighted assets (RWA) and therefore also capital ratios by:\n• enhancing the robustness and risk sensitivity of the standardised approaches for credit risk and\noperational risk, which will help facilitate the comparability of banks' capital ratios;\n• constraining the use of internally modelled approaches, by placing limits on certain inputs used\nto calculate RWA under the internal ratings-based (IRB) approach for credit risk and by removing\nthe use of the modelled approach for operational risk;\n• finalising the leverage ratio, which now includes a buffer to further limit the leverage of global\nsystemically important banks (G-SIBs); and\n• replacing the existing Basel I-based floor with a robust aggregate 72.5% output floor based on\nthe Committee's revised standardised approaches.\nIn order to analyse the impact of the revised standards, the Committee conducted an ad hoc\nBasel III monitoring exercise with the data collection starting in April 2016, in addition to its regular Basel III\nmonitoring exercise2 and the data collection exercise from regulatory reporting systems. This report\nsummarises the aggregate cumulative quantitative impact study results using data jointly from all three\nexercises. The Committee believes that the information contained in the report will provide relevant\nstakeholders with a useful benchmark for analysis as well as provide an estimated impact of the recently\nagreed upon reforms."}], "rationale": "The EU_MICA passages discuss crypto-asset service provision, market abuse prevention, and MiCA's regulatory framework for digital assets. The INT_BASEL_GENERAL passages discuss banking regulation, leverage ratios, and capital adequacy for traditional financial institutions. The obligations and subject matter are distinct; there is no specific obligation in MiCA that pushes against a specific obligation in Basel III. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:89b1312f3ae3473bae0e9db4", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::361::e378", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 16, "passage": "57. ESMA is mandated in Article 84(4) of MiCA to develop, in close cooperation with EBA,\ndraft regulatory technical standards (RTS) on the detailed content of the information for\nthe assessment of proposed acquisitions of qualifying holdings in CASPs. The aim of\nthis draft RTS is to specify the detailed content of the information that direct or indirect\nproposed acquirers must provide to national competent authorities (NCAs) when\nnotifying the intended acquisition. This should ensure a harmonised approach to the\nassessment across Member States in the EU of the intended acquisition of qualifying\nholdings in CASPs.\n\n58. The RTSs are applicable to proposed acquirers of qualifying holdings in CASPs, as well\nas NCAs as designated under Article 93(1) of MiCA that will conduct the assessment of\nthe intended acquisition in accordance with Article 83(4) of MiCA."}], "rationale": "AU_TREASURY_DAP (Australia's proposed DAP framework — Treasury consultation, token-mapping context) and EU_MICA_RTS (EU MiCA regulatory technical standards for CASP authorisation, qualifying-holding acquisitions). Both are crypto-asset service licensing regimes in different jurisdictions with different mechanisms. Distinct perimeters; no obligation conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:45:42Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:2100792674aa35d02b7dc203", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "SG_MAS_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "a82833dc0f7ca903::17a::c743", "source_doc": "Outsourcing_Guidelines_2018.pdf", "page": 3, "passage": "1.2 These Guidelines1 on Outsourcing (\"Guidelines\") set out the Monetary Authority of\nSingapore's (\"MAS\") expectations of an institution that has entered into any outsourcing\narrangement or is planning to outsource its business activities2 to a service provider. An\ninstitution should conduct a self-assessment of all existing outsourcing arrangements against\nthese Guidelines3."}], "rationale": "The evidence for the Australian regime (AU_ATO_CRYPTO) focuses on the taxation of crypto assets and the government's reform agenda (chunk_id e6bb47e92e88e16c::567::36c4). The evidence for the Singaporean regime (SG_MAS_OUTSOURCING) outlines the Monetary Authority of Singapore's (MAS) expectations for institutions managing outsourcing arrangements (chunk_id a82833dc0f7ca903::17a::c743). The obligations in the Australian passage relate to tax compliance and reporting, while the obligations in the Singaporean passage relate to supervisory access and information rights regarding service providers. These are distinct regulatory domains with no apparent overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:13:03Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:3e1a28b8edd57db03e7406ad", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "The EU_NIS2 passage discusses the technical and methodological requirements for access control policies and ICT security measures under Directive (EU) 2022/2555 (NIS2) and Directive (EU) 2022/2557 (Critical Entities Regulation). The SG_STABLECOIN passage outlines the scope of Singapore's stablecoin regulatory regime, specifically focusing on Single-Currency Stablecoins (SCS) issued in Singapore and their treatment under the Payment Services Act 2019. The obligations in the EU_NIS2 passage relate to cybersecurity and access controls for operators of essential and important services, while the obligations in the SG_STABLECOIN passage relate to the issuance and regulation of stablecoins. These are distinct regulatory domains with no apparent overlap of obligations. Therefore, the regimes are in non-conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:08:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:6a3d234ab4752f35725321b1", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}], "rationale": "The evidence for AU_APRA_CPS230 focuses on operational resilience, business continuity, and the management of service providers to ensure critical operations continue through disruptions (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c). The evidence for EU_GDPR focuses on the lawful transfer of personal data to third countries and the general principles governing such transfers (chunk_ids bd84e63f5b622b73::6a8::d132, bd84e63f5b622b73::304::fe8e). The obligations in CPS 230 regarding maintaining critical operations and managing service providers do not directly oppose the GDPR's requirements regarding data transfers. Therefore, the regimes regulate distinct domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:23:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:8aaf8709dc59f4a6743ab689", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::709::b159", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 15, "passage": "2.3 Overview of proposed framework\nLicensing\nThe proposed framework would recognise certain asset holding arrangements as a financial product (a\ndigital asset facility). The existing AFSL framework would apply to any person 'carrying on a financial\nservices business in Australia' in relation to a digital asset facility. Examples of 'financial services'\ninclude:\n• dealing in a financial product (including applying for or acquiring, issuing, varying or disposing of a\nfinancial product)\n• making a market for a financial product\n• providing a custodial or depository service, and\n• providing financial product advice.\nThe issuer of a digital asset facility would be the person or persons responsible for the obligations\nowed to customers under the terms of the asset holding arrangement (platform provider). Platform\nproviders and other intermediaries performing financial services in relation to digital asset facilities\n(e.g. brokers, arrangers, agents, market makers, and advisers) would be required to hold an AFSL.\nWhile the application of the AFSL regime would be jurisdictionally limited to Australia in the usual way,\nan intermediary business in Australia, like a broker, would need to be licensed to provide services that\ninvolve dealing in digital asset facilities generally (including those not licensed or located in Australia).\nSee Part 3 for further detail about licensing obligations.\nFacility contracts\nThe proposed framework would permit digital asset facilities to be paired with other functions,\ncreating digital asset platforms. All arrangements involving digital asset facilities would be required to\nbe structured as non-discretionary arrangements.29 The term 'non-discretionary' means the\narrangements must operate according to pre-agreed and transparent rules and procedures."}], "evidence_b": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "rationale": "The AU_ASIC_AFSL regime regulates the licensing requirements for Australian financial services providers (AFSLs) dealing in digital asset facilities, focusing on the provider's status and financial resources (chunk 550958b067dc6726::709::b159). The EU_REVERSE_SOLICITATION regime addresses the conditions under which third-country crypto-asset service providers can offer services to clients in the EU without authorisation, specifically when the client initiates the relationship (chunk 25cbbd878a1b21d3::4f8::561c). The obligations in Regime A relate to the provider's licensing and financial standing, while Regime B relates to the client's initiative and the provider's solicitation activities. These are distinct regulatory domains; one governs the provider's eligibility to operate, and the other governs the permissible marketing and service provision methods to EU clients. Therefore, there is no direct conflict between the regimes."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:10901e3c3f66815e70269fc3", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::15a::fbf2", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 80, "passage": "Article 63\nCooperation with AMLA\nFIU and supervisory authorities shall cooperate with AMLA and shall provide it with all the information necessary to allow\nit to carry out its duties under this Directive and under Regulations (EU) 2024/1624 and (EU) 2024/1620.\nSECTION 2\nCooperation with other authorities and exchange of confidential information"}, {"chunk_id": "df546f2364aaf9e2::620::328c", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 79, "passage": "Article 62\nCommunication of the list of the competent authorities\n1. In order to facilitate and promote effective cooperation, and in particular the exchange of information, Member States\nshall communicate to the Commission and AMLA:\n(a) the list of supervisors responsible for overseeing the compliance of the obliged entities with Regulation (EU)\n2024/1624, as well as, where relevant, name of the public authority overseeing self-regulatory bodies in their\nperformance of supervisory functions under this Directive, and their contact details;\n(b) the contact details of their FIU;\n(c) the list of other competent national authorities.\n2. For the purposes of paragraph 1, the following contact details shall be provided:\n(a) a contact point or, failing that, the name and role of a contact person;\n(b) the email and phone number of the contact point or, failing that, the professional email address and phone number of\nthe contact person.\nELI: http://data.europa.eu/eli/dir/2024/1640/oj 79/94\n\nEN\n3. Member States shall ensure that the information provided to the Commission and AMLA pursuant to paragraph 1 is\nupdated as soon as a change takes place.\n4. AMLA shall publish a register of the authorities referred to in paragraph 1 on its website and facilitate the exchange of\ninformation referred to in paragraph 2 between competent authorities. The authorities in the register shall, within the scope\nof their powers, serve as a contact point for the counterpart competent authorities. FIUs and supervisory authorities shall\nalso serve as a contact point for AMLA."}], "evidence_b": [{"chunk_id": "6d8a84a9f3d6e9e4::480::ac46", "source_doc": "Guidelines_to_MAS_Notice_SFA04-N02_2025.pdf", "page": 5, "passage": "2 The FSM Sanctions Regulations include the regulations issued under section 192 read with sections 15(1)(b) and 219(d)\nof the FSM Act. Please refer to the following link for the FSM Sanctions Regulations:\nhttps://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions/regulations-for-targeted-financial-\nsanctions. Currently, the relevant FSM Sanctions Regulations are those relating to the Democratic People's Republic of\nKorea and Iran. concerns. Other support functions such as operations, human resource or\ntechnology also play a role to help mitigate the ML/TF risks that the CMI faces. The AML/CFT compliance function is typically the contact point regarding all\nAML/CFT issues for domestic and foreign authorities, including supervisory\nauthorities, law enforcement authorities and financial intelligence units.\n1-4-14 As the third line of defence, the CMI's internal audit function or an equivalent\nfunction plays an important role in independently evaluating the AML/CFT risk\nmanagement framework and controls for purposes of reporting to the audit\ncommittee of the CMI's board of directors, or a similar oversight body."}, {"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "EU_AMLA (EU's Anti-Money Laundering Authority — Articles 62-63 of AMLD6, cooperation with national supervisors) and SG_MAS_AML_GENERAL (MAS's AML/CFT supervisory framework). Both implement AML/CFT supervisory architecture in their jurisdictions consistent with FATF standards. Reinforcing — no obligation conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:01:56Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:13e6a56f3a85672cb2cb6cf5", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "Regime A (AU_TTR_THRESHOLD) regulates the reporting of physical cash transactions exceeding A$10,000 to AUSTRAC. Regime B (INT_BASEL_CRYPTO) regulates the capital requirements and risk weighting of bank exposures to financial institutions. The obligations in Regime A relate to anti-money laundering reporting thresholds for cash, while Regime B addresses prudential capital adequacy for banking institutions. The specific obligations in Regime A do not impose requirements on the capital treatment of exposures or the risk weighting of counterparties, nor do they interact with the Basel framework's definitions of bank exposures or supervisory equivalence. Therefore, the regimes regulate distinct domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:07:48Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:8848463c69dd4765571fab3d", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4a92930a8caf822::380::0a18", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 12, "passage": "Part 1 Preliminary\nSection 1-4\n(a) in relation to registration or proposed registration of a person under Part 6\nof the Act as a remittance network provider-registrable remittance\nnetwork services; or\n(b) in relation to registration or proposed registration of a person under Part 6\nof the Act as an independent remittance dealer or a remittance affiliate of a\nregistered remittance network provider-registrable remittance services; or\n(c) in relation to registration or proposed registration of a person under Part 6A\nof the Act as a virtual asset service provider-registrable virtual asset\nservices.\nrelated body corporate has the same meaning as in the Corporations Act 2001.\nsuper-agent has the meaning given by subsection 4-13(2).\ntracing information, in relation to a transfer of value, means information that\nsatisfies both of the following:\n(a) the information:\n(i) for a transfer from an"}, {"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "rationale": "The regimes regulate distinct aspects of the digital asset ecosystem. Regime A (AU_TRAVEL_RULE) focuses on Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations, specifically the identification of parties in value transfers and the registration of Virtual Asset Service Providers (VASPs) and remittance entities. Evidence A confirms Australia is consulting on extending the FATF 'Travel Rule' to digital currency transactions to improve visibility of beneficial ownership (chunk_ids c4a92930a8caf822::380::0a18, cf7cefacba3f94bc::383::7d9d). Regime B (EU_MICA_TITLE_IV_EMT) focuses on the marketing and disclosure requirements for issuers of e-money tokens, specifically the content and liability associated with crypto-asset white papers. Evidence B outlines the obligation for issuers to notify their crypto-asset white paper to competent authorities and the liability for providing misleading information (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e). There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other; rather, they address separate compliance pillars (AML/CTF vs. Consumer Disclosure)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:24:55Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:f94358fd1732582ff533fa64", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "evidence_b": [{"chunk_id": "14cb9eb911d15322::42b::fe23", "source_doc": "2023_Response_PS_Regulations_Amendments.pdf", "page": 22, "passage": "LTD Question 1. MAS seeks comments on the proposed amendments to the Payment Services\nRegulations.\n1. The term safeguarding institution needs to be defined for the purposes of\nRegulation16C. Since DPTSP can self custodize it would be good to have a clear\ndefinition of safeguarding customer's assets. The term \"safeguarding\" is also not\nused/defined in Securities and Futures Act or in the Securities and Futures\n(licensing and conduct of business) regulations in the context of customer\nassets.\n2. It is not clear in these amendments whether a PSA license is a blanket license\nthat will allow the licensee to conduct all of the digital payment token services\n(i.e. broking dealing in DPT, DPT Exchange, DPT Custody) under one PSA license 2 April 2024 | 26\nor would a licensee be granted a PSA license for specific digital payment token\nservices? Trying to draw an analogy here from the Capital Market Services\nLicense (CMSL) where each CMSL holder is given a license outlining the activities\nthat they can do under the CMSL license.\n8 Interactive Brokers Question 1."}], "rationale": "The EU_NIS2 passage discusses the preparation of technical standards and guidelines for access control policies and resilience measures (chunk_id 3c9eb3a25c93f394::474::4786). The SG_PSA_GENERAL passage discusses the definition of 'safeguarding' for customer assets and the licensing of digital payment token services (chunk_id 14cb9eb911d15322::42b::fe23). The obligations regarding ICT security and access controls under NIS2 do not overlap with the obligations regarding customer asset safeguarding and licensing under the Singapore Payment Services Act. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:55:59Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:e75b8714d416dee2f202a126", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::15a::fbf2", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 80, "passage": "Article 63\nCooperation with AMLA\nFIU and supervisory authorities shall cooperate with AMLA and shall provide it with all the information necessary to allow\nit to carry out its duties under this Directive and under Regulations (EU) 2024/1624 and (EU) 2024/1620.\nSECTION 2\nCooperation with other authorities and exchange of confidential information"}, {"chunk_id": "df546f2364aaf9e2::620::328c", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 79, "passage": "Article 62\nCommunication of the list of the competent authorities\n1. In order to facilitate and promote effective cooperation, and in particular the exchange of information, Member States\nshall communicate to the Commission and AMLA:\n(a) the list of supervisors responsible for overseeing the compliance of the obliged entities with Regulation (EU)\n2024/1624, as well as, where relevant, name of the public authority overseeing self-regulatory bodies in their\nperformance of supervisory functions under this Directive, and their contact details;\n(b) the contact details of their FIU;\n(c) the list of other competent national authorities.\n2. For the purposes of paragraph 1, the following contact details shall be provided:\n(a) a contact point or, failing that, the name and role of a contact person;\n(b) the email and phone number of the contact point or, failing that, the professional email address and phone number of\nthe contact person.\nELI: http://data.europa.eu/eli/dir/2024/1640/oj 79/94\n\nEN\n3. Member States shall ensure that the information provided to the Commission and AMLA pursuant to paragraph 1 is\nupdated as soon as a change takes place.\n4. AMLA shall publish a register of the authorities referred to in paragraph 1 on its website and facilitate the exchange of\ninformation referred to in paragraph 2 between competent authorities. The authorities in the register shall, within the scope\nof their powers, serve as a contact point for the counterpart competent authorities. FIUs and supervisory authorities shall\nalso serve as a contact point for AMLA."}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}, {"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "The EU AMLA regime focuses on the institutional framework for AML/CFT cooperation, information exchange, and supervisory powers (e.g., Article 63 cooperation with AMLA, Article 62 communication of competent authority lists). The Singapore FSMA DTSP regime focuses on the licensing and operational requirements for Digital Token Service Providers (DTSPs), including the definition of DTSPs and the suspension of services outside Singapore by 30 June 2025. The passages describe distinct regulatory domains: one governing the EU AML/CFT institutional structure and the other governing Singaporean licensing for digital token services. There is no specific obligation in the EU AMLA text that creates a conflict with the specific obligations in the Singapore FSMA DTSP text."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:30:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:059c5b5e1ebca0040cb5a11e", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}], "rationale": "The evidence for the Australian regime (AU_ATO_CRYPTO) focuses on the tax treatment and adoption of crypto assets, specifically noting that over 1 million Australians are expected to include crypto assets on their tax returns (chunk_id e6bb47e92e88e16c::567::36c4). The evidence for the EU regime (EU_MICA_TITLE_V_CASP) focuses on the licensing and authorisation requirements for Crypto-Asset Service Providers (CASPs) under the Markets in Crypto-Assets (MiCA) regulation, specifically detailing the application process for authorisation (chunk_id c51ad46265cea4e5::147::6214). The obligations in these passages regulate distinct aspects of the crypto ecosystem—tax compliance versus licensing requirements—and do not impose conflicting mandates on the same entity or transaction."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:16:33Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:00e5e290a38916a7e7207cab", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}, {"chunk_id": "25cbbd878a1b21d3::298::6f7d", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 43, "passage": "28. Third-country firms should be able to provide records tracking the relationship with the\nclient and, in particular, whether the client has taken the initiative to receive crypto asset\nservices with respect to a new product.\n\n5.4 When is a crypto-asset or a crypto-asset service of the same\ntype as another one (Guideline 4)\n\n29. The reverse solicitation regime leaves open the possibility for a third-country firm to\nmarket crypto-assets or crypto-asset services or activities of the same type in the context\nof the relationship started at the own exclusive initiative of a given client, subject to the\nthird-country firm also complying with Guideline 3 above."}], "rationale": "The AU_PRIVACY regime regulates the cross-border disclosure of personal information, requiring entities to take reasonable steps to ensure overseas recipients comply with Australian Privacy Principles (APPs) and making the entity accountable for breaches (chunk_ids e9f6b0a9e797777d::5d6::e5ff, e9f6b0a9e797777d::4ba::1af3). The EU_REVERSE_SOLICITATION regime regulates the provision of crypto-asset services by third-country firms to clients in the EU, specifically defining when authorisation requirements under MiCA do not apply (reverse solicitation) and prohibiting solicitation by the firm (chunk_ids 25cbbd878a1b21d3::4f8::561c, 25cbbd878a1b21d3::298::6f7d). The obligations in these regimes address distinct subject matters—data protection and cross-border information flow versus financial services authorisation and client solicitation. There is no specific obligation in AU_PRIVACY that pushes against a specific obligation in EU_REVERSE_SOLICITATION. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:56:53Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:077f8439e2695fc4e810ae39", "label": "non_conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "The EU GDPR passages discuss data protection principles, lawful processing, and the transfer of personal data to third countries (e.g., Article 6, Article 44, Recital 89). The SG Foundational Legislation passages discuss the Payment Services Act, MAS enforcement actions regarding digital tokens and securities, and the regulatory scope of securities credit schemes (SCS) issued outside Singapore. The obligations in the EU GDPR relate to the protection of personal data, whereas the obligations in the SG legislation relate to the regulation of payment services and financial market conduct. The passages do not describe a specific obligation in one regime that pushes against a specific obligation in the other; rather, they regulate distinct domains. Therefore, the regimes are in non-conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:5162eff41dcf0d19d015a238", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "1393876621ff1b2d::215::b185", "source_doc": "Guidance-Criminalising-Terrorist-Financing.pdf.coredownload.inline.pdf", "page": 3, "passage": "4. This guidance is based on the same general principles that govern both the interpretation and\nassessment of the FATF standards. As noted in the introduction to the 2012 FATF\n\"Countries have diverse legal, administrative and operational frameworks and different\nRecommendations:\nfinancial systems, and so cannot all take identical measures to counter these threats. The FATF\nRecommendations, therefore, set an international standard, which countries should implement\nthrough measures adapted to their particular circumstances.\"\nhow"}], "rationale": "AU_FEDREG_AML (Australian AML/CTF Act and Rules) and INT_FATF_GENERAL (FATF AML/CFT principles and guidance). Australia explicitly implements FATF standards through its AML/CTF framework. Reinforcing."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:53:16Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:bf38de6ca13324d20723ca82", "label": "non_conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "adb1a81b9cecaf8c::3ac::b555", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 16, "passage": "(89) Provision of payment services by the payment services providers may entail processing of personal data. Directive\n95/46/EC of the European Parliament and of the Council ( 1) , the national rules which transpose Directive 95/46/EC\nand Regulation (EC) No 45/2001 of the European Parliament and of the Council ( 2 ) are applicable to the\nprocessing of personal data for the purposes of this Directive. In particular, where personal data is processed\nfor the purposes of this Directive, the precise purpose should be specified, the relevant legal basis referred to, the\nrelevant security requirements laid down in Directive 95/46/EC complied with, and the principles of necessity,\nproportionality, purpose limitation and proportionate data retention period respected. Also, data protection by\ndesign and data protection by default should be embedded in all data processing systems developed and used\nwithin the framework of this Directive."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}, {"chunk_id": "f173909614befd49::4bf::1d9e", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "Specific disclosure requirements should be augmented by a general disclosure\nrequirement.\n111 See Principles for Periodic Disclosure by Listed Entities, Final Report, Report of the Technical Committee\nof IOSCO, February 2010, pp. 16-17, available at\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD317.pdf; see also Protection of Minority\nShareholders in Listed Issuers, Final Report, Report of the Technical Committee of IOSCO in consultation\nwith the OECD, June 2009, pp.10-14, available at\nhttps://www.iosco.org/library/pubdocs/pdf/IOSCOPD295.pdf; see also International Disclosure Standards\nfor Cross-Border Offerings and Initial Listings by Foreign Issuers, supra, Item VII at pp. 18-19;\nDisclosure Principles for Public Offerings and Listings of Asset-backed Securities, supra, Principle III at\npp. 10-12; and International Disclosure Principles for Cross-Border Offerings and Listing of Debt\nSecurities by Foreign Issuers, Final Report, Report of the Technical Committee of IOSCO, March 2007,\nItem XI at pp. 23-24, available at https://www.iosco.org/library/pubdocs/pdf/IOSCOPD242.pdf.\n112 If there are classes of shares or other structural features that would affect share price, these should be\ndisclosed."}], "rationale": "The EU GDPR passages regulate the processing of personal data, including legal bases, purpose limitation, and transfers to third countries (chunk_ids bd84e63f5b622b73::6a8::d132, bd84e63f5b622b73::304::fe8e, adb1a81b9cecaf8c::3ac::b555). The INT_IOSCO_GENERAL passages regulate securities regulation, disclosure standards, and methodology for issuers (chunk_ids f173909614befd49::455::1a1a, f173909614befd49::4bf::1d9e). The obligations in the GDPR relate to data protection and privacy, while the obligations in IOSCO relate to financial market integrity and disclosure. There is no specific obligation in the GDPR that pushes against a specific obligation in IOSCO; rather, they govern distinct domains of regulation."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:33:44Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:35af683be7ce40a806524e64", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}, {"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The EU MICA Title IV EMT passages regulate the specific disclosure obligations of issuers of e-money tokens, including the requirement to notify a crypto-asset white paper to a competent authority and the liability for misleading information (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e). The MAS TRM passages discuss general feedback on the application of guidelines to licensees, the principles-based nature of the TRM Guidelines, and the Fit and Proper criteria (chunk_ids 20d526d712753652::403::be97, 20d526d712753652::401::f956). The obligations in the EU regime are specific to the content and notification of a white paper, whereas the MAS regime addresses general licensing, governance principles, and risk management. There is no specific obligation in the MAS regime that directly conflicts with the EU's white paper notification or liability requirements. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:26:12Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:b3a8ecf617a09897f34f441d", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "The EU_MAR regime regulates market abuse, insider dealing, and market manipulation in financial markets (chunk 5cc4a27bc578287a::165::3333). The SG_PSA_DPT regime regulates the licensing and AML/CFT obligations of Digital Payment Token (DPT) service providers under the Payment Services Act (chunk 4b4c3c417dc293ba::185::f41d). The obligations in the EU_MAR passage relate to the integrity of financial markets and the prevention of market abuse, while the obligations in the SG_PSA_DPT passage relate to the licensing and anti-money laundering controls of payment service providers. These are distinct regulatory domains with no apparent overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:38:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:711affd43fb3448275d331b2", "label": "non_conflict", "regime_a": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "Regime A (INT_IOSCO_GENERAL) is a high-level methodology and principles document regarding securities regulation and disclosure standards. Regime B (SG_PSA_DPT) is a Singaporean regulatory notice (MAS Notice PSN02) specifically governing Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) obligations for Digital Payment Token (DPT) service providers. The cited passages from Regime A discuss the general objectives of IOSCO and the importance of disclosure standards, while the cited passages from Regime B establish the legal basis and scope of AML/CFT licensing requirements for DPT providers in Singapore. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B; rather, they regulate distinct aspects of the financial system (general securities regulation vs. specific AML/CFT licensing for digital assets). Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:41:37Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:a2adf79ed5a17b6785d4998a", "label": "conflict", "regime_a": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "IRAS", "short_name": "SG_IRAS_TAX"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "SG_MAS_AML_GENERAL"}, "conflict_type": "recurring_friction", "severity": "low", "evidence_a": [{"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}, {"chunk_id": "abc2247bc6415d1d::5c7::68f5", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 10, "passage": "You should obtain the sum of the absolute values of\nexempt supplies from each category to report in your GST return. Category of exempt supplies Exchange gain (loss) for digital\nfor the accounting period from payment tokens\nJan 2020 to Mar 2020\nExchange gain (loss) for digital (200)\npayment tokens Exchange gain (loss) for foreign 400\ncurrency\nInterest received from deposit with 300\nbanks\nValue of exempt supplies |(200)| + 400 + 300\n= $900\nQ9 Can I report the value of supply of digital payment tokens issued during\nmy ICO based on the proceeds received, and then report the value of\nsupply for subsequent transactions based on realised gain or loss? A9 Yes, you may report the proceeds received as the value of supply for ICO\ntransactions. For subsequent exchanges of the tokens for fiat currency or\nother digital payment tokens, you may choose to report the realised gain or\nloss. This is allowed as long as you apply the method chosen consistently.\n14 Contact information\n10.1 For enquiries on this e-Tax Guide, please contact the Goods and Services\nTax Division at www.iras.gov.sg (select \"Contact Us\")\n15 Updates and Amendments\nDate of\nAmendments made\namendment\n1 3 Aug 2022 • Editorial changes.\n• Amended paragraphs 3.6 and 3.8 to reflect the\ndefinition in Income Tax e-Tax Guide on digital\npayment tokens.\n• Added paragraph 5.11 to clarify that if a digital\npayment token is listed on an exchange, IRAS will\nregard the token as suitable for use as a medium\nof exchange."}], "evidence_b": [{"chunk_id": "417228836d7e2aa3::379::317d", "source_doc": "MAS_Notice_PSN02_2024-04-02_rev_2025-06-30.pdf", "page": 2, "passage": "or\n(b) means an FX counterparty;\n\"relevant FX counterparty\" is a FX counterparty that is not ⎯\n(a) a financial institution as defined in section 2 of the FSM Act; or\n(b) a financial institution incorporated or established outside Singapore that is subject\nto, and supervised for compliance with, AML/CFT requirements consistent with\nstandards set by the FATF;\n\"SFA\" means the Securities and Futures Act 2001;\n\"STR\" means suspicious transaction report;\n\"STRO\" means the Suspicious Transaction Reporting Office, Commercial Affairs\nDepartment of the Singapore Police Force;\n\"transaction\" means any transaction accepted, processed, or executed by the payment\nservice provider in the course of carrying on its business of providing a digital payment\ntoken service;\n\"trust relevant party\" has the same meaning as defined in paragraph 2.1 of MAS Notice\nTCA-N03;\n[MAS Notice PSN02 (Amendment) 202"}, {"chunk_id": "d6f4be6b9d136778::4ae::d5ed", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 67, "passage": "27 These offences typically relate to cybersecurity issues such as unauthorised access. addition, MAS' off-site monitoring will also enable us to identify and target specific\nkey risks and initiate supervisory follow-up actions including for-cause inspections\nas necessary. Payment Services Act 2019\nII-3-2 ML/TF risks have been identified as the primary risk concerns posed by virtual\nassets, given the anonymity, speed and cross-border nature of transactions\nfacilitated by virtual asset providers. Under the Payment Services Act 2019 (PS\nAct), MAS will impose AML/CFT requirements on the intermediaries that buy, sell\nor exchange virtual assets in Singapore - these are the VASP business models\nidentified to be operating in Singapore. II-3-3 Under the PS Act, aligned with the FATF standards, DPT service providers are\nrequired to conduct customer due diligence and transaction monitoring measures,\nas well as to report suspicious transactions to the authorities. They are also\nrequired to screen and submit information on their customers when transferring\nDPTs to one another on behalf of their customers, and make this information\navailable on request to appropriate authorities in Singapore."}], "rationale": "SG_IRAS_TAX (Singapore tax framework) and SG_MAS_AML_GENERAL (MAS's broader AML/CFT supervisory framework including FSM Sanctions Regulations and PSN02 AML notice for DPT providers). Same recurring-friction shape: every transaction at a regulated entity generates parallel obligations under both regimes — IRAS tax recordkeeping/reporting AND MAS AML supervision. Severity low; the regimes are designed to coexist but each imposes per-transaction overhead independently.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:52Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:09:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:8c36a126aadf8d82192adada", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}], "rationale": "The obligations in APRA CPS 230 relate to operational risk management, business continuity, and the resilience of critical operations for APRA-regulated entities (chunk_ids f296a7e0bead93df::4a5::9828, f296a7e0bead93df::5e9::d5f4). In contrast, the obligations in EU MAR relate to the prevention and detection of market abuse, insider dealing, and market manipulation (chunk_id 5cc4a27bc578287a::165::3333). The regimes regulate distinct domains—prudential operational resilience versus market integrity and conduct—resulting in no overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:93499cdd9fc099b297a703c4", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DAC 8"}, "regime_b": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::4d9::6684", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 25, "passage": "B. Due diligence procedures for Entity Crypto-Asset Users\nThe following procedures apply for the purpose of determining whether the Entity Crypto-Asset User is a Reportable\nUser or an Entity, other than an Excluded Person or an Active Entity, with one or more Controlling Persons who are\nReportable Persons.\n1. Determine whether the Entity Crypto-Asset User is a Reportable Person. (a) When establishing the relationship with the Entity Crypto-Asset User, or with respect to Pre-existing Entity\nCrypto-Assets Users by 1 January 2027, the Reporting Crypto-Asset Service Provider shall obtain a self-\ncertification that allows the Reporting Crypto-Asset Service Provider to determine the Entity Crypto-Asset\nUser's residence(s) for tax purposes and confirm the reasonableness of such self-certification based on the\ninformation obtained by the Reporting Crypto-Asset Service Provider, including any documentation collected\npursuant to Customer Due Diligence Procedures. If the Entity Crypto-Asset User certifies that it has no\nresidence for tax purposes, the Reporting Crypto-Asset Service Provider may rely on the place of effective\nmanagement or the address of the principal office to determine the residence of the Entity Crypto-Asset User."}, {"chunk_id": "c0300673081f7232::667::5080", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 25, "passage": "A Reporting Crypto-Asset Service Provider is subject to the reporting and due diligence requirements set out in Sections\nII and III, respectively, in a Member State with respect to Reportable Transactions effectuated through a Branch based in\na Member State. C. A Reporting Crypto-Asset Service Provider that is an Entity is not required to complete the reporting and due diligence\nrequirements set out in Sections II and III, respectively, in a Member State it is subject to pursuant to subparagraph A(2),\npoint (b), (c) or (d), if those requirements are completed by such Reporting Crypto-Asset Service Provider in any other\nMember State or in a Qualified Non-Union Jurisdiction by virtue of it being resident for tax purposes in such Member\nState or Qualified Non-Union Jurisdiction. D. A Reporting Crypto-Asset Service Provider that is an Entity is not required to complete the reporting and due diligence\nrequirements set out in Sections II and III, respectively, in a Member State it is subject to pursuant to subparagraph A(2),\npoint (c) or (d), if those requirements are completed by such Reporting Crypto-Asset Service Provider in any other\nMember State or in a Qualified Non-Union Jurisdiction by virtue of it being an Entity that (a) is incorporated or\norganised under the laws of such Member State or Qualified Non-Union Jurisdiction and (b) either has legal personality\nin the other Member State or Qualified Non-Union Jurisdiction or has an obligation to file tax returns or tax\ninformation returns to the tax authorities in the other Member State or Qualified Non-Union Jurisdiction with respect\nto the income of the Entity."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}, {"chunk_id": "85307f9e2a040982::36a::b013", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 38, "passage": "27.12.2022 EN Official Journal of the European Union L 333/39\n(h) implement, as appropriate, relevant operational conclusions resulting from the tests referred to in point (g) and from\npost-incident analysis into the ICT risk assessment process and develop, according to needs and ICT risk profile, ICT\nsecurity awareness programmes and digital operational resilience training for staff and management.\n2. The ICT risk management framework referred to in paragraph 1, second subparagraph, point (a), shall be documented\nand reviewed periodically and upon the occurrence of major ICT-related incidents in compliance with supervisory\ninstructions. It shall be continuously improved on the basis of lessons derived from implementation and monitoring. A\nreport on the review of the ICT risk management framework shall be submitted to the competent authority upon its\nrequest.\n3."}], "rationale": "DAC8 is a tax-reporting directive; DORA is an ICT-resilience regulation. The two apply to overlapping populations (an EU CASP is in scope of both) but address completely different subject matters: customer / transaction tax data exchange vs ICT risk management framework. No collision possible at the obligation level. Hard negative.", "would_conflict_if": ["DORA ICT incident-reporting timelines forced disclosure of personal data that DAC8 confidentiality rules limited — current text gives each regime its own confidentiality framework."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:44:43Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:719fb3ddc5a53ef264a438bd", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "evidence_b": [{"chunk_id": "14cb9eb911d15322::42b::fe23", "source_doc": "2023_Response_PS_Regulations_Amendments.pdf", "page": 22, "passage": "LTD Question 1. MAS seeks comments on the proposed amendments to the Payment Services\nRegulations.\n1. The term safeguarding institution needs to be defined for the purposes of\nRegulation16C. Since DPTSP can self custodize it would be good to have a clear\ndefinition of safeguarding customer's assets. The term \"safeguarding\" is also not\nused/defined in Securities and Futures Act or in the Securities and Futures\n(licensing and conduct of business) regulations in the context of customer\nassets.\n2. It is not clear in these amendments whether a PSA license is a blanket license\nthat will allow the licensee to conduct all of the digital payment token services\n(i.e. broking dealing in DPT, DPT Exchange, DPT Custody) under one PSA license 2 April 2024 | 26\nor would a licensee be granted a PSA license for specific digital payment token\nservices? Trying to draw an analogy here from the Capital Market Services\nLicense (CMSL) where each CMSL holder is given a license outlining the activities\nthat they can do under the CMSL license.\n8 Interactive Brokers Question 1."}], "rationale": "Regime A (INT_BASEL_CRYPTO) regulates capital requirements and risk-weighting for bank exposures to financial institutions, including securities firms and central counterparties. Regime B (SG_PSA_GENERAL) regulates the licensing and conduct of digital payment token services in Singapore. The obligations in Regime A relate to prudential capital adequacy and risk management for banks, while the obligations in Regime B relate to the licensing scope and definition of 'safeguarding' for digital payment token service providers. The passages describe distinct regulatory domains with no apparent overlap of obligations. Therefore, the regimes are in non_conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:22:18Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:1323f5d2d6fb93ecd4e5ac49", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::709::b159", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 15, "passage": "2.3 Overview of proposed framework\nLicensing\nThe proposed framework would recognise certain asset holding arrangements as a financial product (a\ndigital asset facility). The existing AFSL framework would apply to any person 'carrying on a financial\nservices business in Australia' in relation to a digital asset facility. Examples of 'financial services'\ninclude:\n• dealing in a financial product (including applying for or acquiring, issuing, varying or disposing of a\nfinancial product)\n• making a market for a financial product\n• providing a custodial or depository service, and\n• providing financial product advice.\nThe issuer of a digital asset facility would be the person or persons responsible for the obligations\nowed to customers under the terms of the asset holding arrangement (platform provider). Platform\nproviders and other intermediaries performing financial services in relation to digital asset facilities\n(e.g. brokers, arrangers, agents, market makers, and advisers) would be required to hold an AFSL.\nWhile the application of the AFSL regime would be jurisdictionally limited to Australia in the usual way,\nan intermediary business in Australia, like a broker, would need to be licensed to provide services that\ninvolve dealing in digital asset facilities generally (including those not licensed or located in Australia).\nSee Part 3 for further detail about licensing obligations.\nFacility contracts\nThe proposed framework would permit digital asset facilities to be paired with other functions,\ncreating digital asset platforms. All arrangements involving digital asset facilities would be required to\nbe structured as non-discretionary arrangements.29 The term 'non-discretionary' means the\narrangements must operate according to pre-agreed and transparent rules and procedures."}], "evidence_b": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "rationale": "Regime A (AU_ASIC_AFSL) establishes a licensing framework for financial services and digital asset facilities, specifically requiring platform providers to hold an Australian Financial Services Licence (AFSL) to carry on a financial services business in Australia (chunk 550958b067dc6726::709::b159). Regime B (EU_AMLR_TFR) focuses on Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) obligations, extending AML/CFT rules to crypto-asset service providers and requiring information accompanying transfers of funds (chunk c0300673081f7232::279::1918). The obligations in Regime B relate to the traceability and reporting of transactions for AML/CFT purposes, whereas Regime A relates to the licensing and conduct of financial services providers. These are distinct regulatory domains; the AML/CFT obligations do not conflict with the AFSL licensing requirements, nor do they impose specific operational constraints that would prevent a compliant AFSL holder from operating in the EU context."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:39:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:4dd6a2e841d84c1572cbc530", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "3d9b3d4849297e91::3c6::7b85", "source_doc": "2025_CP_Prudential_Treatment_Cryptoassets.pdf", "page": null, "passage": "Preface | 4\n1.6 MAS invites comments from banks and other interested parties. Please refer to Annex A for the list of\nquestions.\n1.7 Please note that all submissions received will be published and attributed to the respective respondent\nunless they expressly request MAS not to do so. As such, if respondents would like\n(a) their whole submission or part of it (but not their identity), or\n(b) their identity along with their whole submission,\nto be kept confidential, please expressly state so in the submission to MAS. MAS will only publish\nnon-anonymous submissions. In addition, MAS reserves the right not to publish any submission\nreceived where MAS considers it not in the public interest to do so, such as where the submission\nappears to be libelous or offensive.\n1.8 Please submit written comments via email to prudential_policy_dept@mas.gov.sg using the suggested\ntemplate by 28 April 2025. Prudential Treatment & Disclosures of Cryptoasset Exposures | 5\n2."}, {"chunk_id": "7c04f2a0bd85290a::46d::fd1b", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "Binance is supportive of the redemption-related requirements. In general, five business\ndays should be sufficient to return the par value of the SCS to customers. However, given\nthat this is ultimately dependent on the availability of the relevant banking services,\nBinance would propose that this is aligned to the prevailing turnaround time provided by\nthe financial institution that the reserve assets are held with. Question 7. MAS seeks comments on whether the prudential requirements outlined in paragraph\n4.21 are risk proportionate. MAS welcomes suggestions on alternative approaches to\naddress the risks. Binance is supportive of the prudential requirements outlined in paragraph 4.21. 15 August 2023 | 23\nQuestion 10. MAS seeks comments on whether the scenario outlined in paragraph 4.22 is a likely\ndevelopment and whether the approaches outlined in paragraph 4.24 are feasible. MAS\nwelcomes suggestions on other approaches to address this issue. As per Q1, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction."}], "rationale": "The regimes regulate distinct aspects of the digital asset ecosystem. Regime A (AU_ASIC_CRYPTO) focuses on the licensing and classification of crypto-assets as financial products and services under the Corporations Act (chunk_ids abc9007e907ef318::3c9::4151, abc9007e907ef318::5a2::9ff3). Regime B (SG_MAS_PRUDENTIAL_CRYPTO) focuses on the prudential treatment and capital requirements for cryptoasset exposures, specifically stablecoins and payment services (chunk_ids 3d9b3d4849297e91::3c6::7b85, 7c04f2a0bd85290a::46d::fd1b). The evidence shows no specific obligation in one regime that directly contradicts or conflicts with a specific obligation in the other; rather, they address different regulatory domains (licensing vs. prudential capital)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:19:24Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:9d505a9fcdaa748a3ba870ce", "label": "conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "AU_ATO_CRYPTO (Australian Taxation Office crypto-asset tax framework — capital-gains reporting, recordkeeping, and ATO information requests on Australian taxpayers' crypto-asset disposals) and SG_PDPA (Singapore PDPA — consent-based collection/disclosure restrictions). When AU exchanges and crypto-asset operators serve customers who are SG-resident or who hold data in SG (e.g. SG-based custodians of AU taxpayers' crypto), ATO reporting and information-request compliance can require transmitting personal data from SG to AU. PDPA restricts the SG-side outbound flow. Operationally resolvable via PDPA s.13(b) ('required or authorised by law') in combination with international tax-information-exchange agreements. Same shape as the labelled DAC8 × PDPA conflict, applied to AU-SG tax-reporting context. Severity low because cross-jur ATO reporting is narrower than DAC8's structured cross-border reporting and resolution paths are well-established.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:38Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.75, "record_type": "conflict", "pair_id": "conflict:425340d4e9ee36c765678537", "label": "conflict", "regime_a": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "IRAS", "short_name": "SG_IRAS_TAX"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "conflict_type": "recurring_friction", "severity": "low", "evidence_a": [{"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}, {"chunk_id": "abc2247bc6415d1d::5c7::68f5", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 10, "passage": "You should obtain the sum of the absolute values of\nexempt supplies from each category to report in your GST return. Category of exempt supplies Exchange gain (loss) for digital\nfor the accounting period from payment tokens\nJan 2020 to Mar 2020\nExchange gain (loss) for digital (200)\npayment tokens Exchange gain (loss) for foreign 400\ncurrency\nInterest received from deposit with 300\nbanks\nValue of exempt supplies |(200)| + 400 + 300\n= $900\nQ9 Can I report the value of supply of digital payment tokens issued during\nmy ICO based on the proceeds received, and then report the value of\nsupply for subsequent transactions based on realised gain or loss? A9 Yes, you may report the proceeds received as the value of supply for ICO\ntransactions. For subsequent exchanges of the tokens for fiat currency or\nother digital payment tokens, you may choose to report the realised gain or\nloss. This is allowed as long as you apply the method chosen consistently.\n14 Contact information\n10.1 For enquiries on this e-Tax Guide, please contact the Goods and Services\nTax Division at www.iras.gov.sg (select \"Contact Us\")\n15 Updates and Amendments\nDate of\nAmendments made\namendment\n1 3 Aug 2022 • Editorial changes.\n• Amended paragraphs 3.6 and 3.8 to reflect the\ndefinition in Income Tax e-Tax Guide on digital\npayment tokens.\n• Added paragraph 5.11 to clarify that if a digital\npayment token is listed on an exchange, IRAS will\nregard the token as suitable for use as a medium\nof exchange."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}, {"chunk_id": "4b4c3c417dc293ba::170::3d86", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": null, "passage": "MAS Notice PSN02\n5 December 2019\nNOTICE TO HOLDERS OF PAYMENT SERVICE LICENCE (DIGITAL PAYMENT TOKEN\nSERVICE)\nMONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186\nPREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF\nTERRORISM - HOLDERS OF PAYMENT SERVICE LICENCE (DIGITAL PAYMENT TOKEN\nSERVICE)\n______________________________________________________________________"}], "rationale": "SG_IRAS_TAX (IRAS Singapore tax framework — including the GST exemption for DPTs from 1 Jan 2020) and SG_PSA_DPT (PSA DPT-service licensing — AML and operational obligations). The IRAS framework treats DPTs differently from fiat for GST but still requires recordkeeping and reporting of transactions for income-tax / capital-gains purposes. Combined with PSA's per-transaction AML obligations, DPT-service providers bear ongoing per-transaction recordkeeping and classification overhead. Severity low because the GST carve-out reduces some friction.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:37Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:54:03Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:58459ffc3fc524b8ab931e33", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "Regime A (AU_APRA_CPS230) regulates operational risk management, business continuity, and service provider management for APRA-regulated entities. Regime B (SG_FSMA_DTSP) regulates the licensing and conduct of Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022. The obligations in Regime A focus on internal resilience and risk management frameworks (e.g., identifying critical operations, managing service provider risks) [f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c]. The obligations in Regime B focus on the licensing status and conduct of DTSPs, specifically requiring a licence to conduct digital token services in Singapore [cc1be49e9cf8c821::2f4::ea8f]. While a DTSP operating in Singapore would be subject to APRA's CPS 230 if it is an APRA-regulated entity (e.g., an Australian bank), the specific obligations of the DTSP regime (licensing, FATF alignment) do not directly contradict the operational risk management requirements of CPS 230. The regimes regulate distinct aspects of the entity's operations: one on the conduct of digital token services and licensing, the other on the management of operational risks and resilience. Therefore, the regimes are in different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:16:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:58459ffc3fc524b8ab931e33", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "Regime A (AU_APRA_CPS230) regulates operational risk management, business continuity, and service provider management for APRA-regulated entities. Regime B (SG_FSMA_DTSP) regulates the licensing and conduct of Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022. The obligations in Regime A focus on internal resilience and risk management frameworks (e.g., identifying critical operations, managing service provider risks) [f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c]. The obligations in Regime B focus on the licensing status and conduct of DTSPs, specifically requiring a licence to conduct digital token services in Singapore [cc1be49e9cf8c821::2f4::ea8f]. While a DTSP operating in Singapore would be subject to APRA's CPS 230 if it is an APRA-regulated entity (e.g., an Australian ADI), the specific obligations of the DTSP regime (licensing, FATF alignment) do not directly contradict the operational risk management requirements of CPS 230. The regimes regulate distinct aspects of the entity's operations: one on the prudential management of operational risk and resilience, the other on the regulatory status and conduct of digital token services. Therefore, the regimes are in different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:8c2d3e900ddd289f8f374055", "label": "conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "conflict_type": "structural_unresolved", "severity": "high", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}], "rationale": "AU_TREASURY_DAP (Australia's proposed Digital Asset Platforms licensing regime — Treasury's framework for entities operating crypto-asset platforms in Australia) and SG_FSMA_DTSP (Singapore's Digital Token Service Provider licensing under FSM Act 2022 Part 9 — required licence for entities providing digital token services in or from Singapore, including extraterritorial reach). Both regimes establish parallel entity-licensing frameworks for the same economic activity (operating a digital-asset / digital-token platform for clients). The tension is STRUCTURAL: neither regime contains an equivalence, mutual-recognition, or transit pathway letting an entity authorised under one operate under the other. Identical pattern to the careful-cohort labelled AU_TREASURY_DAP ↔ EU_MICA_TITLE_V_CASP conflict (session 7), in AU↔SG framing.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:48Z", "decision": "accept", "notes": "", "original_conflict_type": "structural_unresolved", "original_severity": "high", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:5ee8f2ef295993f4e291b6a6", "label": "conflict", "regime_a": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::284::b4a8", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 38, "passage": "94. The FATF Standards, including the definitions of virtual assets and VASPs, represent\na minimum standard for countries to introduce. In line with the RBA, countries may\nchoose to extend their AML/CFT regimes to include other digital assets and entities,\nbeyond the FATF definition of virtual asset and VASP. Such a determination should\nbe made on the basis of a ML/TF risk assessment, with consideration of the\nchallenges associated with regulatory divergence.\n\nUPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS  37\nPART THREE:\nAPPLICATION OF FATF STANDARDS TO COUNTRIES AND\nCOMPETENT AUTHORITIES"}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}, {"chunk_id": "0e996ae99839f19e::61d::14e5", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "23 Act 2012 2020Ed. Deemed consent by notification\n15A.-(1) This section applies to the collection, use or disclosure\nof personal data about an individual by an organisation on or after\n1 February 2021.\n[40/2020]\n(2) Subject to subsection (3), an individual is deemed to consent to\nthe collection, use or disclosure of personal data about the individual\nby an organisation if -\n(a) the organisation satisfies the requirements in\nsubsection (4); and\n(b) the individual does not notify the organisation, before the\nexpiry of the period mentioned in subsection (4)(b)(iii),\nthat the individual does not consent to the proposed\ncollection, use or disclosure of the personal data by the\norganisation.\n[40/2020]\n(3) Subsection(2)doesnotapplytothecollection,useordisclosure\nof personal data about the individual for any prescribed purpose.\n[40/2020]\n(4) For the purposes of subsection (2)(a), the organisation must,\nbefore collecting, using or disclosing any personal data about the\nindividual -\n(a) conduct an assessment to determine that the proposed\ncollection, use or disclosure of the personal data is not\nlikely to have an adverse effect on the individual;\n(b) take reasonable steps to bring the following information to\nthe attention of the individual:\n(i) theorganisation'sintentiontocollect,useordisclose\nthe personal data;\n(ii) the purpose for which the personal data will be\ncollected, used or disclosed;\n(iii) a reasonable period within which, and a reasonable\nmanner by which, the individual may notify the\norganisation that the individual does not consent to"}], "rationale": "INT_FATF_VASP (FATF VASP standards mandating collection and sharing of originator/beneficiary identity for crypto transfers — Recommendation 16 / travel rule) and SG_PDPA (Singapore Personal Data Protection Act restricting collection, use and disclosure of personal data without consent or specific legal authorisation). When SG-licensed VASPs implement FATF travel rule, they must collect and share personal data of senders/recipients; PDPA's consent requirements would restrict this absent the 'required or authorised under any other written law' carve-out (PDPA s.13(b)). Operationally resolvable via that statutory carve-out plus MAS's AML/CFT notice framework that establishes the legal authorisation. Same shape as labelled AU AML/CTF ↔ AU PRIVACY conflict in the careful cohort, translated to the FATF↔SG-PDPA cross-jurisdictional framing.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:24:04Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:39:40Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:45edbc63357aa749a2fd9376", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}], "rationale": "The AU_ATO_CRYPTO passage discusses the token mapping of crypto assets in Australia and the tax implications for over 1 million Australians holding crypto. The FATF_R16 passage outlines the FATF's role in protecting the global financial system against money laundering and terrorist financing. The two regimes regulate distinct domains: one focuses on tax compliance and asset classification for Australian entities, while the other establishes global AML/CFT standards. There is no specific obligation in the AU_ATO_CRYPTO passage that conflicts with the FATF_R16 standards, nor is there evidence that the FATF standards impose a specific tax obligation on Australian entities that would contradict the ATO's guidance."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:8b4800083c727291472307cd", "label": "conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}, {"chunk_id": "33d059aa86716ddd::4ed::8511", "source_doc": "2022_CP_Stablecoin_Regulatory_Approach.pdf", "page": 6, "passage": "3.5 A wide range of stablecoins currently exist, varying in terms of their asset-\npegging, as well as the mechanism that upholds the stability of the stablecoins' value\nagainst the pegged asset(s). MAS intends to focus its regulatory regime on:\nSingle-currency pegged stablecoins (SCS) - As compared to other types of\nstablecoins (such as those pegged to a basket of currencies or other\nassets such as commodities), SCS has a stronger use case for payment and\nsettlement.\nNon-SCS will continue to be subject to the existing DPT regime under the\nPS Act. MAS views such stablecoins as being less stable in nominal value\nand should be treated differently from SCS.\nIn addition, even among SCS, there is variation in the stabilisation\nmechanism. MAS views stablecoins which are algorithmically-pegged,\nunbacked or backed by other cryptocurrencies to be more susceptible to\nvolatility in value. Correspondingly, such stablecoins will also continue to\nbe treated as DPTs.\nSCS issued in Singapore - The immediate priority of MAS is to elevate the\nstandard of SCS issued in Singapore. Our regulatory perimeter is thus\nscoped based on MAS' ability to directly impose requirements on the\nreserve management, redemption policies and prudential standards of\nthe SCS issuer."}], "rationale": "AU_ASIC_CRYPTO (ASIC INFO 225 — financial-product classification of crypto-assets) and SG_STABLECOIN (MAS SCS framework — Singapore-issued single-currency stablecoin classification). Whether a stablecoin instrument qualifies as an SG SCS vs as an AU financial product turns on FACTS about peg mechanism, issuer location, and reserve structure. Each regime's classification has different downstream obligations.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:15Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.7, "record_type": "conflict", "pair_id": "conflict:4a3577b4f962f1fb271bd0f8", "label": "conflict", "regime_a": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "IRAS", "short_name": "SG_IRAS_TAX"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "conflict_type": "recurring_friction", "severity": "low", "evidence_a": [{"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}, {"chunk_id": "abc2247bc6415d1d::5c7::68f5", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 10, "passage": "You should obtain the sum of the absolute values of\nexempt supplies from each category to report in your GST return. Category of exempt supplies Exchange gain (loss) for digital\nfor the accounting period from payment tokens\nJan 2020 to Mar 2020\nExchange gain (loss) for digital (200)\npayment tokens Exchange gain (loss) for foreign 400\ncurrency\nInterest received from deposit with 300\nbanks\nValue of exempt supplies |(200)| + 400 + 300\n= $900\nQ9 Can I report the value of supply of digital payment tokens issued during\nmy ICO based on the proceeds received, and then report the value of\nsupply for subsequent transactions based on realised gain or loss? A9 Yes, you may report the proceeds received as the value of supply for ICO\ntransactions. For subsequent exchanges of the tokens for fiat currency or\nother digital payment tokens, you may choose to report the realised gain or\nloss. This is allowed as long as you apply the method chosen consistently.\n14 Contact information\n10.1 For enquiries on this e-Tax Guide, please contact the Goods and Services\nTax Division at www.iras.gov.sg (select \"Contact Us\")\n15 Updates and Amendments\nDate of\nAmendments made\namendment\n1 3 Aug 2022 • Editorial changes.\n• Amended paragraphs 3.6 and 3.8 to reflect the\ndefinition in Income Tax e-Tax Guide on digital\npayment tokens.\n• Added paragraph 5.11 to clarify that if a digital\npayment token is listed on an exchange, IRAS will\nregard the token as suitable for use as a medium\nof exchange."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::45b::7c2f", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "However, to ensure market integrity and public trust, it is critical that all\nsingle-labelled SCS meet the same regulatory requirements. As a result, we support the\nMAS's proposal for single-labelled SCS, but only under the condition that non-banks would\nbe also subject the same regulatory requirements for their SCS issuance services. Moreover, we would recommend that MAS adopts the term \"regulated stablecoins\" as we\nfind that it reflects MAS's aspiration to develop a digital assets ecosystem by introducing a\nrobust regulatory framework for SCS. In parallel, we believe that it would be beneficial if\nSCS issuers would be able to add on the single label of SCS, e.g. \"regulated stablecoin -\nCompany A\". This could help customers differentiate their SCS offerings, encourage\ncompetition and consequently attract more issuers and contribute to the development of\nthe digital asset ecosystem. Question 5. MAS seeks comments on whether the proposed reserve asset requirements are\nappropriate, and whether there may be unintended consequences that may affect the\ndevelopment of Singapore's digital asset ecosystem."}, {"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "SG_IRAS_TAX (IRAS Singapore tax framework including DPT GST treatment) and SG_STABLECOIN (MAS SCS framework — SG-issued stablecoin issuer obligations). SCS issuers face ongoing recordkeeping, reserve attestation, and redemption-event reporting under MAS framework; combined with IRAS recordkeeping requirements, every issuance/redemption generates parallel reporting friction. Low severity due to the GST exemption simplifying one side.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:40Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:01cf45cf0b80588b0a8f480b", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::284::b4a8", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 38, "passage": "94. The FATF Standards, including the definitions of virtual assets and VASPs, represent\na minimum standard for countries to introduce. In line with the RBA, countries may\nchoose to extend their AML/CFT regimes to include other digital assets and entities,\nbeyond the FATF definition of virtual asset and VASP. Such a determination should\nbe made on the basis of a ML/TF risk assessment, with consideration of the\nchallenges associated with regulatory divergence.\n\nUPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS  37\nPART THREE:\nAPPLICATION OF FATF STANDARDS TO COUNTRIES AND\nCOMPETENT AUTHORITIES"}], "evidence_b": [{"chunk_id": "018117ef1e757630::428::d321", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Strengthening AML/CFT Controls of\nDigital Payment Token Service Providers\nMarch 2021 Introduction\nThis infographic sets out recent international developments and MAS' supervisory expectations on\nAML/CFT controls for the Digital Payment Token (DPT) sector.\n• This infographic is intended to raise industry awareness to the money laundering and terrorism financing (ML/TF)\nrisks in the DPT sector, and provide additional supervisory information to help DPT service providers implement\neffective policies, procedures and controls to deal with the ML/TF risks.\n• In particular, this infographic focuses on:\nI) Financial Action Task Force (FATF) Standards and recent developments;\nII) ML/TF Risks in DPT sector; and\nIII) Overview of MAS' AML/CFT requirements and expectations for the DPT sector - including key AML/CFT\nconsiderations relating to new DPT products, enhanced customer due diligence (ECDD) and value transfer.\n• The infographic supplements existing AML/CFT requirements, and should be read in conjunction with the Notice\nPS-N02 and accompanying Guidelines."}], "rationale": "INT_FATF_VASP (FATF VASP standards as a minimum international AML/CFT framework) and SG_AML (MAS's AML/CFT controls for DPT service providers in Singapore). Singapore explicitly implements FATF VASP guidance through its supervisory regime; the regimes reinforce each other."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:b1181e6edba7c0e963f10dea", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU AML/CTF (AUSTRAC guidance)"}, "regime_b": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "ASIC crypto-asset guidance"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}], "evidence_b": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): AUSTRAC AML/CTF operational guidance and ASIC's crypto-asset INFO 225 / RG 282 guidance operate in disjoint regulatory domains at the obligation level. AUSTRAC AML supervision and ASIC market-conduct supervision address disjoint obligation surfaces on potentially overlapping populations. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:22:39Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:f4f33bbca08e8cfa82436dc3", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "The EU_MICA_RTS passage discusses the notification obligations of financial entities providing crypto-asset services under MiCA (chunk_id c51ad46265cea4e5::2f5::4513). The SG_MAS_AML_GENERAL passage discusses the risk-based supervision of Digital Payment Token (DPT) providers and the application of AML/CFT regulations to entities dealing with DPTs (chunk_id b49627bb889ef1d9::1b6::0802). While both regimes regulate crypto-assets, the specific obligations cited—notification under MiCA and risk-based supervision/AML/CFT compliance under MAS—are distinct and do not impose conflicting requirements. The SG passage focuses on the regulatory framework and supervision of DPT providers, whereas the EU passage focuses on the notification process for entities providing crypto-asset services. Therefore, the regimes are in different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:15:44Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.7, "record_type": "conflict", "pair_id": "conflict:4567011c8e20e87c2699c01d", "label": "conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}, {"chunk_id": "0e996ae99839f19e::3d0::2bb3", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "2020Ed. Act 2012 20\n(2) An organisation must not -\n(a) as a condition of providing a product or service, require an\nindividual to consent to the collection, use or disclosure of\npersonal data about the individual beyond what is\nreasonable to provide the product or service to that\nindividual; or\n(b) obtain or attempt to obtain consent for collecting, using or\ndisclosing personal data by providing false or misleading\ninformationwithrespecttothecollection,useordisclosure\nof the personal data, or using deceptive or misleading\npractices. (3) Anyconsentgiveninanyofthecircumstancesinsubsection(2)\nis not validly given for the purposes of this Act. (4) InthisAct,referencestoconsentgiven,ordeemedtohavebeen\ngiven, by an individual for the collection, use or disclosure of\npersonal data about the individual include consent given, or deemed\nto have been given, by any person validly acting on that individual's\nbehalf for the collection, use or disclosure of such personal data."}], "rationale": "EU_PSD2 (Article 97 strong-customer-authentication for payment service providers, plus Article 95-101 data-protection coordination requiring PSPs to process personal data only to the extent necessary for payment-service provision) and SG_PDPA (consent-based collection/disclosure restrictions in Singapore). EU PSPs handling SG-resident clients' payment data must transmit account/transaction data cross-border; PDPA restricts the SG-side flow. Operationally resolvable via PDPA s.13(b) and via PSD2's built-in GDPR compatibility provisions read with SG PSA carve-outs. Severity low because PSD2's own data-protection framework already coordinates with GDPR — the cross-jur tension is narrower but real.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:27Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:02:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:f865801260aac184480926bb", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::34e::4d5c", "source_doc": "d424.pdf", "page": 84, "passage": "141. Section G discusses the method by which the difference between provisions (eg specific\nprovisions, portfolio-specific general provisions such as country risk provisions or general provisions) and\nexpected losses may be included in or must be deducted from regulatory capital, as outlined in the\ndefinition of capital section of the Basel III framework (June 2011).\n\n1. Calculation of expected losses\n\n142. A bank must sum the EL amount (defined as EL multiplied by EAD) associated with its exposures\nto which the IRB approach is applied (excluding the EL amount associated with securitisation exposures)\nto obtain a total EL amount. The treatment of EL for securitisation exposures is described in paragraph 37\nof the securitisation framework.\n(i) Expected loss for exposures other than exposures subject to the supervisory slotting\ncriteria"}], "rationale": "The EU_MAR passages regulate market conduct, specifically insider dealing, market manipulation, and the prevention of market abuse by market operators and investment firms (chunk_ids 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The INT_BASEL_GENERAL passages regulate banking supervision, capital adequacy, and leverage ratios, focusing on the treatment of fiduciary assets, provisions, and expected losses (chunk_ids 32afd37cade34f84::34b::8d30, 32afd37cade34f84::34e::4d5c). The obligations in EU_MAR relate to the integrity of financial markets and investor protection through conduct rules, while the obligations in INT_BASEL_GENERAL relate to the resilience of the banking system through capital and leverage requirements. There is no specific obligation in EU_MAR that pushes against a specific obligation in INT_BASEL_GENERAL; they regulate distinct domains of financial regulation."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:05:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:43611b830101eb58e0152145", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}], "rationale": "The evidence for APRA CPS234 (chunk 4b6fab404e7acfca::3c4::1564) establishes that the document is a 'Prudential Practice Guide' which offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230, but explicitly states that the guide 'do not themselves create enforceable requirements.' The evidence for the EU GDPR (chunk bd84e63f5b622b73::6a8::d132) discusses the legal basis for processing personal data. Because the APRA passage confirms the document is non-binding guidance rather than a binding regulatory obligation, there is no specific obligation in APRA that pushes against a specific obligation in the GDPR. The regimes regulate different things (operational risk management guidance vs. data protection law), resulting in no conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:37:39Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:c46eda91a9d1a537dc8f54ee", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::340::9399", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 21, "passage": "1. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n2. MiCA sets out a new legal framework applicable to legal persons or other undertakings\nintending to provide crypto-asset services, requiring such entities to submit an\napplication for authorisation containing all the information set out in Article 62(2) of MiCA,\nas specified by the RTS on the information for authorisation as a CASP.\n\n3. The next paragraphs present the cost-benefit analysis of the main policy options included\nin this final report on the requirements for the application for authorisation as a CASP\nunder Article 62 of MiCA.\nProblem identification"}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "The EU MiCA passages (c51ad46265cea4e5::147::6214, c51ad46265cea4e5::340::9399) describe the requirements for obtaining authorisation as a Crypto-Asset Service Provider (CASP) and the establishment of a public register. The Singapore foundational legislation passages (7c04f2a0bd85290a::413::fc6a) discuss MAS's regulatory approach to Security Token Offerings (STOs) and the potential for recognizing foreign SCS (Security Token Offerings) that meet equivalent standards, specifically mentioning SCS issued under EU MiCA regulation. The regimes regulate distinct aspects of the crypto-asset ecosystem: MiCA focuses on the licensing and registration of service providers, while the Singapore text focuses on the regulatory treatment of specific token offerings and cross-border enforcement. There is no evidence of a direct obligation in MiCA that conflicts with a specific obligation in the Singapore foundational legislation."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:5d99d3258595c718ae2134c4", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EMD2"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiFID II"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6bbad50f6b09cc9d::27e::94d4", "source_doc": "EMD2_Directive_EU_2009-110.pdf", "page": 6, "passage": "Article 4\ntution to hold an amount of own funds which is up to 20 %\nInitial capital higher than the amount which would result from the appli\ncation of the relevant method in accordance with paragraph\nMember States shall require electronic money institutions to\n2, or permit the electronic money institution to hold an\nhold, at the time of authorisation, initial capital, comprised of\namount of own funds which is up to 20 % lower than the\nthe items set out in Article 57(a) and (b) of Directive\namount which would result from the application of the\n2006/48/EC, of not less than EUR 350 000.\nrelevant method in accordance with paragraph 2."}, {"chunk_id": "6bbad50f6b09cc9d::5c6::4d5d", "source_doc": "EMD2_Directive_EU_2009-110.pdf", "page": 10, "passage": "Article 20\nprohibited from issuing electronic money. Amendments to Directive 2006/48/EC\nDirective 2006/48/EC is hereby amended as follows:\n2. Member States may provide for an electronic money insti\ntution to be automatically granted authorisation and entered in\nthe register provided for in Article 3 if the competent 1. Article 4 is amended as following:\nauthorities already have evidence that the electronic money\ninstitution concerned complies with the requirements laid\ndown in Articles 3, 4 and 5. The competent authorities shall (a) point 1 is replaced by the following:\ninform the electronic money institutions concerned before the\nauthorisation is granted.\n'1. \"credit institution\" means an undertaking the business\nof which is to receive deposits or other repayable\nfunds from the public and to grant credits for its\n3. Member States shall allow electronic money institutions\nown account;'\nthat have taken up, before 30 April 2011, activities in\naccordance with national law transposing Article 8 of\nDirective 2000/46/EC, to continue those activities within the (b) point 5 is replaced by the following:\nMember State concerned in accordance with Directive\n2000/46/EC until 30 April 2012, without being required to\nseek authorisation under Article 3 of this Directive or to '5. \"financial institution\" means an undertaking other\ncomply with the other provisions laid down or referred to in than a credit institution, the principal activity of\nTitle II of this Directive."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::49c::69f4", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 53, "passage": "Member States shall require that investment firms and market operators operating an MTF or an OTF establish,\npublish and maintain and implement transparent and non-discriminatory rules, based on objective criteria, governing\naccess to its facility.\n4. Member States shall require that investment firms and market operators operating an MTF or an OTF have\narrangements to identify clearly and manage the potential adverse consequences for the operation of the MTF or OTF,\nor for the members or participants and users, of any conflict of interest between the interest of the MTF, the OTF, their\nowners or the investment firm or market operator operating the MTF or OTF and the sound functioning of the MTF or\nOTF.\n5. Member States shall require that investment firms and market operators operating an MTF or OTF comply with\nArticles 48 and 49 and have in place all the necessary effective systems, procedures and arrangements to do so.\n6. Member States shall require that investment firms and market operators operating an MTF or an OTF clearly inform\nits members or participants of their respective responsibilities for the settlement of the transactions executed in that\nfacility."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "rationale": "EMD2 regulates electronic money institutions (issuance, redemption, own funds); MiFID II regulates investment firms (financial instruments, trading venues, suitability). The two directives apply to substantively different populations and address different products. An EMI is not by default an investment firm; a MiFID II investment firm is not by default an EMI. Easy hard negative.", "would_conflict_if": ["A hybrid entity authorised under both would face cumulative obligations rather than conflicting ones."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:8df5e61d67e39038644a10de", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "rationale": "AU_APRA_CPS230 (APRA Operational Risk Management — preventing disruption to critical operations) and EU_NIS2 (EU Network and Information Security Directive — ICT access controls and cybersecurity). Both touch on operational/cyber resilience but at different layers — APRA CPS 230 is broad operational risk management; NIS2 is specifically network and information security. Distinct mechanisms and scope."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:10:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:e00a7e04ea11860043bf6ef4", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4a92930a8caf822::380::0a18", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 12, "passage": "Part 1 Preliminary\nSection 1-4\n(a) in relation to registration or proposed registration of a person under Part 6\nof the Act as a remittance network provider-registrable remittance\nnetwork services; or\n(b) in relation to registration or proposed registration of a person under Part 6\nof the Act as an independent remittance dealer or a remittance affiliate of a\nregistered remittance network provider-registrable remittance services; or\n(c) in relation to registration or proposed registration of a person under Part 6A\nof the Act as a virtual asset service provider-registrable virtual asset\nservices.\nrelated body corporate has the same meaning as in the Corporations Act 2001.\nsuper-agent has the meaning given by subsection 4-13(2).\ntracing information, in relation to a transfer of value, means information that\nsatisfies both of the following:\n(a) the information:\n(i) for a transfer from an"}, {"chunk_id": "c4a92930a8caf822::57d::3f76", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 28, "passage": "Part 4-Registration\nDivision 1-Management of the Remittance Sector Register and the\nVirtual Asset Service Provider Register\n4-1 Correction of entries\n(1) This section is made for the purposes of paragraphs 75(4)(a) and 76B(4)(a) of the\nAct. (2) If the AUSTRAC CEO reasonably believes that there is an error in, or omission\nfrom, an entry in the Remittance Sector Register or the Virtual Asset Service\nProvider Register, the AUSTRAC CEO may correct the error or omission. (3) As soon as reasonably practicable after making a correction of an entry under\nthis section, the AUSTRAC CEO must give notice of the correction to:\n(a) the person whose registration the entry relates to; and\n(b) if the registration is of a person as a remittance affiliate of a registered\nremittance network provider-the provider.\n4-2 Publication of register information\n(1) For the purposes of subsections 75(4) and 76B(4) of the Act, the AUSTRAC\nCEO must publish the following on AUSTRAC's website:\n(a) the details mentioned in paragraphs 75A(1)(a), (b), (c) and (f) of the Act on\nthe Remittance Sector Register;\n(b) the details mentioned in paragraphs 76C(a) and (d) of the Act on the\nVirtual Asset Service Provider Register;\n(c) information mentioned in section 4-24 of this instrument (register entry in\nrelation to suspension of registration) on the Remittance Sector Register\nand the Virtual Asset Service Provider Register."}, {"chunk_id": "c4a92930a8caf822::37f::8a4f", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 98, "passage": "mentioned in item 2 (ii) tracing information\ndo not apply\n4 the transfer of value is a merchant payment card number of the card the payer used in\nrelation to the merchant payment\n5 the transfer of value is a refund of a card number of the card the payer used in\nmerchant payment relation to the merchant payment that is\nrefunded\n6 the instruction for the transfer of value is card number of the card the payer used in\ngiven by the use of an ATM relation to the withdrawal\n7 (a) the value being transferred is money; and tracing information\n(b) the money is in a foreign country and, as\na result of the provision of an\ninternational value transfer service, the\nmoney will be in Australia; and\n(c) the beneficiary institution receives the\ntransfer message for the transfer of value\nthrough BECS\n8 the value is transferred from a self-hosted (a) payer information; and\nvirtual asset wallet (b) the"}, {"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "26ddcee02677b25f::245::fab6", "source_doc": "CDSA_Corruption_Drug_Trafficking_Confiscation_Act_1992.pdf", "page": null, "passage": "THE STATUTES OF THE REPUBLIC OF SINGAPORE\nCORRUPTION, DRUG TRAFFICKING\nAND OTHER SERIOUS CRIMES\n(CONFISCATION OF BENEFITS)\nACT 1992\n2020REVISEDEDITION\nThisrevisededitionincorporatesallamendmentsuptoand\nincluding1December2021andcomesintooperationon31December2021.\nPreparedandPublishedby\nTHELAWREVISIONCOMMISSION\nUNDERTHEAUTHORITYOF\nTHEREVISEDEDITIONOFTHELAWSACT1983\n\n2020Ed.\nAct 1992\nARRANGEMENT OF SECTIONS\n\nPART 1\nPRELIMINARY\nSection\n1. Short title\n2. General interpretation\n3. Meaning of \"item subject to legal privilege\"\n4. Application\n5. Suspicious Transaction Reporting Office"}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "6644db515eb0e280::1ec::5ae7", "source_doc": "Payment_Services_Act_2019.pdf", "page": 213, "passage": "Parliament\nS Subsidiary Legislation\nS.I. Statutory Instrument (United Kingdom)\nS (N.S.) Subsidiary Legislation (New Series)\nS.S.G.G. Straits Settlements Government Gazette\nS.S.G.G. (E) Straits Settlements Government Gazette (Extraordinary) COMPARATIVE TABLE\nPAYMENT SERVICES ACT 2019\nThis Act has undergone renumbering in the 2020 Revised Edition. This\nComparativeTableisprovidedtohelpreaderslocatethecorrespondingprovisions\nin the last Revised Edition.\n2020 Ed. Act 2 of 2019\n1-(1) and (2) 1"}, {"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "The AU_TRAVEL_RULE passages discuss the Australian regulatory framework for remittance networks and virtual asset service providers, including the status of the FATF 'Travel Rule' implementation (cf7cefacba3f94bc::383::7d9d, 30a32a386d15ba2b::4f3::edc3). The SG_FOUNDATIONAL_LEGISLATION passages discuss the Payment Services Act and MAS's regulatory approach to digital tokens and securities, including the intention to align with international AML/CFT requirements (b49627bb889ef1d9::3ef::7168, d6f4be6b9d136778::467::12af). While both regimes reference FATF standards and the Travel Rule, the AU passages describe the *status* of implementation (consultation, partial application), whereas the SG passages describe the *scope* of the Payment Services Act and MAS's enforcement actions. There is no evidence of a specific obligation in one regime that directly contradicts or conflicts with a specific obligation in the other; rather, they address the same topic (AML/CFT compliance for virtual assets) from different jurisdictional perspectives. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:09:33Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:52193b8952941201343cc18c", "label": "conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "20d526d712753652::1a4::2e6e", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Notabene commend's the Monetary Authority of Singapore (MAS) for proposing a\ncomprehensive and detailed regulatory approach for Digital Token Service Providers\n(DTSPs) under the Financial Services and Markets Act 2022. Our comments focus on\nthe alignment of these notices and guidelines with international standards,\nparticularly in light of Financial Action Task Force (FATF) Recommendations,\nincluding the Travel Rule."}, {"chunk_id": "20d526d712753652::4b9::b812", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": 71, "passage": "(Please refer to paragraph 12 of the draft FSM Notice). The proposed requirements for Correspondent Account Services (CAS) in paragraph\n5.6 of the draft FSM Notice are both applicable and appropriate for the digital token\nservice provider (DTSP) sector. Given the inherent cross-border nature and rapid\ntransactions within digital token services, the FATF-aligned risk mitigation measures\nensure that DTSPs are aligned with global AML/CFT standards, providing a secure\nframework for correspondent services while addressing potential ML/TF risks. Applicability of Risk Mitigation Measures\nThe requirement for DTSPs to assess the suitability of financial institutions when\nproviding or receiving CAS, including evaluating their AML/CFT controls, is essential\nfor preventing potential misuse of these services. The dynamic and often cross-\njurisdictional interactions in digital token services make these standards particularly\nrelevant to ensuring consistent risk management. MAS could consider offering\nguidance on specific factors DTSPs should evaluate, such as transaction monitoring\ncapabilities and the jurisdiction's regulatory reputation, to better equip licensees in\napplying a comprehensive assessment."}], "rationale": "AU_PRIVACY (APP 8 cross-border disclosure of personal information — requires reasonable steps to ensure overseas recipient compliance with APPs) and SG_FSMA_DTSP (Singapore Digital Token Service Provider licensing under FSM Act 2022 Part 9 — including extraterritorial AML/CFT obligations on DTSP licensees including customer due diligence and recordkeeping for cross-border transactions). When AU APP entities provide personal information to SG DTSPs for transaction processing (e.g. originator/beneficiary data under travel-rule obligations), APP 8's overseas-disclosure requirements engage. Operationally resolvable via APP 6.2(b) (use or disclosure required or authorised by law) plus APP 8.2(d) (permitted general situations). Same shape as labelled AU AML/CTF ↔ AU PRIVACY conflict, in AU↔SG cross-jurisdictional framing.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:22Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:57:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:72684d117d21465f7394e0a7", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "a0d157539d5c8040::2fc::beb4", "source_doc": "FinalReport_Market_Abuse_Guidelines_MiCA.pdf", "page": 6, "passage": "2 Background and Legal Basis\nArticle 92 (3) of MiCA:\nIn order to ensure consistency of supervisory practices under this Article, ESMA shall by 30\nJune 2025 issue guidelines in accordance with Article 16 of Regulation (EU) No 1095/2010 on\nsupervisory practices among the competent authorities to prevent and detect market abuse, if\nnot already covered by the regulatory technical standards referred to in paragraph 2.\n\n1. To promote confidence in markets in crypto-assets and ensure their integrity, Title VI of\nMiCA lays down rules on prevention and prohibition of market abuse involving crypto\nassets.\n\n2. Article 92(1) of MiCA requires any PPAET in crypto-assets to have in place effective\narrangements, systems and procedures to prevent and detect market abuse."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::46d::fd1b", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "Binance is supportive of the redemption-related requirements. In general, five business\ndays should be sufficient to return the par value of the SCS to customers. However, given\nthat this is ultimately dependent on the availability of the relevant banking services,\nBinance would propose that this is aligned to the prevailing turnaround time provided by\nthe financial institution that the reserve assets are held with. Question 7. MAS seeks comments on whether the prudential requirements outlined in paragraph\n4.21 are risk proportionate. MAS welcomes suggestions on alternative approaches to\naddress the risks. Binance is supportive of the prudential requirements outlined in paragraph 4.21. 15 August 2023 | 23\nQuestion 10. MAS seeks comments on whether the scenario outlined in paragraph 4.22 is a likely\ndevelopment and whether the approaches outlined in paragraph 4.24 are feasible. MAS\nwelcomes suggestions on other approaches to address this issue. As per Q1, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction."}], "rationale": "The EU_MICA passage (chunk_id a0d157539d5c8040::2fc::beb4) outlines a legal framework for crypto-assets, specifically mentioning the prevention of market abuse and the provision of crypto-asset services. The SG_MAS_PRUDENTIAL_CRYPTO passage (chunk_id 7c04f2a0bd85290a::46d::fd1b) discusses the prudential requirements for Stablecoin Issuers (SCS) and the need for a robust regulatory framework to address market integrity and consumer protection. While both regimes address crypto-assets, the EU passage focuses on market abuse prevention and service provision, whereas the SG passage focuses on prudential treatment and capital requirements for issuers. The obligations are complementary rather than conflicting, as they address different aspects of the crypto-asset ecosystem (market integrity vs. financial stability)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:f5066d326a3a102f858b2758", "label": "conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "rationale": "AU_AML_CTF (Australian AML/CTF Act mandating reporting-entity collection and disclosure of customer information to AUSTRAC) and EU_GDPR (EU regulation restricting transfer and processing of personal data to third countries — recognised as compatible only via Chapter V mechanisms). When an AU reporting entity has EU-resident customers and reports their data to AUSTRAC, this engages GDPR cross-border transfer restrictions. Operationally resolvable via GDPR Article 6(1)(c) (legal-obligation lawful basis) plus Chapter V transfer mechanism (SCCs or derogation under Art. 49). Same conflict shape as the labelled EU TFR ↔ EU GDPR conflict in the careful cohort, in AU-EU cross-jurisdictional framing.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:41Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:02:56Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:7f80f6e28fae122f113c969f", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "The EU_PSD2 passages regulate the technical security of payment transactions, specifically mandating 'strong customer authentication' and the protection of 'personalised security credentials' (chunk_ids adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b). The SG_AML passages regulate the conduct of financial institutions regarding money laundering and terrorism financing, focusing on training, due diligence, and reporting suspicious transactions (chunk_id 3d521e61e49aaf46::38f::e615). The obligations are distinct: one concerns the technical integrity of payment authentication, while the other concerns the compliance culture and risk management of AML/CFT. There is no specific obligation in PSD2 that pushes against a specific obligation in SG_AML, nor do the regimes regulate the same thing. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:98f1adbe0680ad412777437c", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title IV (EMT)"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "3a1785f95cb37b3c::336::8d0b", "source_doc": "AMLA_Regulation_EU_2024-1620.pdf", "page": 32, "passage": "The list of\nthe selected obliged entities shall be published by the Authority without undue delay upon completion of the selection\nprocess. The Authority shall commence direct supervision of the selected obliged entities six months after publication of\nthe list.\n5. Prior to the publication of the list of the selected obliged entities, the Authority shall inform the relevant\nnon-AML/CFT authorities of the outcomes of the process of assessment and classification of inherent and residual risk of\nthe obliged entities subject to assessment.\n6. A selected obliged entity shall remain subject to direct supervision by the Authority until the Authority commences\nthe direct supervision of selected obliged entities based on a list established for the subsequent selection period which no\nlonger includes that obliged entity."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::53d::70f2", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 13, "passage": "(66)\nIssuers of e-money tokens should be authorised either as a credit institution under Directive 2013/36/EU or as an\nelectronic money institution under Directive 2009/110/EC. E-money tokens should be deemed to be 'electronic\nmoney' as that term is defined in Directive 2009/110/EC and their issuers should, unless specified otherwise in\nthis Regulation, comply with the relevant requirements set out in Directive 2009/110/EC for the taking up,\npursuit and prudential supervision of the business of electronic money institutions and the requirements on\nissuance and redeemability of e-money tokens. Issuers of e-money tokens should draw up a crypto-asset white\npaper and notify it to their competent authority. Exemptions regarding limited networks, regarding certain\ntransactions by providers of electronic communications networks and regarding electronic money institutions\nissuing only a limited maximum amount of electronic money, based on the optional exemptions specified in\nDirective 2009/110/EC, should also apply to e-money tokens. However, issuers of e-money tokens should still be\nrequired to draw up a crypto-asset white paper in order to inform buyers about the characteristics and risks of\nthe e-money tokens and should also be required to notify the crypto-asset white paper to the competent authority\nbefore its publication."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLA Regulation establishing the AML supervisor and EU MiCA Title IV e-money-token issuer regime are designed to coexist — obligations apply cumulatively without collision. AMLA supervises EMT-issuer CASPs as AMLR-obliged entities — aligned. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:26:56Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b289bb4274c14c7f9a7cb8fc", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "The FATF passages (chunk_id fe52dd87e13dba41::261::59a4) provide general international guidance on anti-money laundering (AML) and counter-terrorist financing (CTF) principles, noting that financial inclusion and AML/CFT serve complementary objectives. The Singapore PSA DPT passages (chunk_id 4b4c3c417dc293ba::185::f41d) detail the specific legal framework for digital payment token service providers under the Payment Services Act 2019. While both regimes address AML/CFT obligations, the Singapore regime is a specific jurisdictional implementation of the general FATF principles. The passages do not describe a specific obligation in one regime that pushes against a specific obligation in the other; rather, they describe the same topic (AML/CFT) from different perspectives (general international standard vs. specific national regulation)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:15:44Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:0be1cf65d63b5442eca1f009", "label": "conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}, {"chunk_id": "0e996ae99839f19e::3d0::2bb3", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "2020Ed. Act 2012 20\n(2) An organisation must not -\n(a) as a condition of providing a product or service, require an\nindividual to consent to the collection, use or disclosure of\npersonal data about the individual beyond what is\nreasonable to provide the product or service to that\nindividual; or\n(b) obtain or attempt to obtain consent for collecting, using or\ndisclosing personal data by providing false or misleading\ninformationwithrespecttothecollection,useordisclosure\nof the personal data, or using deceptive or misleading\npractices. (3) Anyconsentgiveninanyofthecircumstancesinsubsection(2)\nis not validly given for the purposes of this Act. (4) InthisAct,referencestoconsentgiven,ordeemedtohavebeen\ngiven, by an individual for the collection, use or disclosure of\npersonal data about the individual include consent given, or deemed\nto have been given, by any person validly acting on that individual's\nbehalf for the collection, use or disclosure of such personal data."}], "rationale": "EU_MIFID2 (investment-firm KYC, client suitability assessment, client categorisation, transaction reporting under MiFID II/MiFIR) and SG_PDPA (Singapore PDPA). EU investment firms providing services to SG-resident clients must collect detailed personal/financial data and may transmit suitability assessments and transaction reports cross-border. PDPA restricts the SG-side collection/disclosure. Operationally resolvable via PDPA s.13(b) 'required or authorised by law' plus PDPA's third-party-disclosure framework. Same shape as the labelled EU TFR ↔ EU GDPR conflict, applied to investment-services KYC.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:29Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T06:30:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:63791464b5370f3daac89f24", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EMD2"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title IV (EMT)"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "6bbad50f6b09cc9d::27e::94d4", "source_doc": "EMD2_Directive_EU_2009-110.pdf", "page": 6, "passage": "Article 4\ntution to hold an amount of own funds which is up to 20 %\nInitial capital higher than the amount which would result from the appli\ncation of the relevant method in accordance with paragraph\nMember States shall require electronic money institutions to\n2, or permit the electronic money institution to hold an\nhold, at the time of authorisation, initial capital, comprised of\namount of own funds which is up to 20 % lower than the\nthe items set out in Article 57(a) and (b) of Directive\namount which would result from the application of the\n2006/48/EC, of not less than EUR 350 000.\nrelevant method in accordance with paragraph 2."}, {"chunk_id": "6bbad50f6b09cc9d::37f::45df", "source_doc": "EMD2_Directive_EU_2009-110.pdf", "page": 9, "passage": "Article 18(2) and in so far as this Directive provides for\nmore of the activities listed in Article 6(1)(e) and it is\nharmonisation, Member States shall not maintain or introduce\nunknown in advance what proportion of funds is to be\nprovisions other than those laid down in this Directive.\nused as electronic money, all funds requested by the elec\ntronic money holder shall be redeemed.\n2. Member States shall ensure that an electronic money\n7. Notwithstanding paragraphs 4, 5 and 6, redemption rights issuer does not derogate, to the detriment of an electronic\nof a person, other than a consumer, who accepts electronic money holder, from the provisions of national law imple\nmoney shall be subject to the contractual agreement between menting or corresponding to provisions of this Directive\nthe electronic money issuer and that person. except where explicitly provided for therein.\n\nArticle 12"}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::53d::70f2", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 13, "passage": "(66)\nIssuers of e-money tokens should be authorised either as a credit institution under Directive 2013/36/EU or as an\nelectronic money institution under Directive 2009/110/EC. E-money tokens should be deemed to be 'electronic\nmoney' as that term is defined in Directive 2009/110/EC and their issuers should, unless specified otherwise in\nthis Regulation, comply with the relevant requirements set out in Directive 2009/110/EC for the taking up,\npursuit and prudential supervision of the business of electronic money institutions and the requirements on\nissuance and redeemability of e-money tokens. Issuers of e-money tokens should draw up a crypto-asset white\npaper and notify it to their competent authority. Exemptions regarding limited networks, regarding certain\ntransactions by providers of electronic communications networks and regarding electronic money institutions\nissuing only a limited maximum amount of electronic money, based on the optional exemptions specified in\nDirective 2009/110/EC, should also apply to e-money tokens. However, issuers of e-money tokens should still be\nrequired to draw up a crypto-asset white paper in order to inform buyers about the characteristics and risks of\nthe e-money tokens and should also be required to notify the crypto-asset white paper to the competent authority\nbefore its publication."}, {"chunk_id": "491a2f0014d56ffb::3f8::b0ef", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 68, "passage": "Article 49\nIssuance and redeemability of e-money tokens\n1.\nBy way of derogation from Article 11 of Directive 2009/110/EC, in respect of the issuance and redeemability of e-\nmoney tokens only the requirements set out in this Article shall apply to issuers of e-money tokens.\n2.\nHolders of e-money tokens shall have a claim against the issuers of those e-money tokens.\n3.\nIssuers of e-money tokens shall issue e-money tokens at par value and on the receipt of funds.\nEN\nL 150/107\n\n4.\nUpon request by a holder of an e-money token, the issuer of that e-money token shall redeem it, at any time and\nat par value, by paying in funds, other than electronic money, the monetary value of the e-money token held to the\nholder of the e-money token.\n5.\nIssuers of e-money tokens shall prominently state the conditions for redemption in the crypto-asset white paper as\nreferred to in Article 51(1), first subparagraph, point (d).\n6.\nWithout prejudice to Article 46, the redemption of e-money tokens shall not be subject to a fee."}], "rationale": "MiCA Title IV explicitly builds on EMD2: MiCA Recital 66 stipulates that EMT issuers must be authorised as a credit institution or as an EMI under Directive 2009/110/EC (EMD2). MiCA Article 49 derogates from EMD2 Article 11 only in respect of EMT issuance and redeemability, and does so deliberately to carry the issuance-and-redemption-at-par principle into the crypto context. The two regimes are aligned by design — MiCA Title IV is the crypto-specific overlay on the underlying EMD2 authorisation. No EMD2 obligation pushes against any MiCA Title IV obligation; the seed pair note flagged this as expected structural_unresolved but the rubric walk resolves it as a negative (aligned, not conflicting).", "would_conflict_if": ["EBA-level RTS under MiCA imposed an EMT-specific own-funds floor inconsistent with EMD2 Article 5 — Level-2 work has not produced such a collision."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:82d7769cecc7681efc6eb187", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "ba862e1f095bceac::1a6::1f0e", "source_doc": "FATF Recommendations 2012.pdf.coredownload.inline.pdf", "page": 79, "passage": "4. A country need not impose a separate licensing or registration system with respect to natural\nor legal persons already licensed or registered as financial institutions (as defined by the FATF\nRecommendations) within that country, which, under such license or registration, are\npermitted to perform VASP activities and which are already subject to the full range of\napplicable obligations under the FATF Recommendations."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "INT_FATF_VASP (FATF VASP guidance — international AML/CFT standards) and SG_MAS_AML_GENERAL (MAS's AML/CFT supervisory framework for DPT providers). FATF establishes the minimum; SG implements via MAS notices. Reinforcing relationship — same regulatory concern, different layers of the hierarchy."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:09:27Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:81f547f7a71b1aa1f84b85da", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "evidence_b": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}, {"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The EU DAC8 regime focuses on tax transparency and the automatic exchange of information regarding crypto-asset users (chunk_ids c0300673081f7232::320::7b46, c0300673081f7232::498::163c). In contrast, the MAS TRM regime addresses operational risk management, internal processes, and the application of principles-based guidelines to licensees (chunk_ids 20d526d712753652::403::be97, 20d526d712753652::401::f956). The obligations in DAC8 relate to reporting to tax authorities, while the obligations in MAS TRM relate to internal governance and risk assessment. These are distinct regulatory domains with no apparent overlap or conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:05:04Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:4d6d26fb3ab49da0bab832c7", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4a92930a8caf822::380::0a18", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 12, "passage": "Part 1 Preliminary\nSection 1-4\n(a) in relation to registration or proposed registration of a person under Part 6\nof the Act as a remittance network provider-registrable remittance\nnetwork services; or\n(b) in relation to registration or proposed registration of a person under Part 6\nof the Act as an independent remittance dealer or a remittance affiliate of a\nregistered remittance network provider-registrable remittance services; or\n(c) in relation to registration or proposed registration of a person under Part 6A\nof the Act as a virtual asset service provider-registrable virtual asset\nservices.\nrelated body corporate has the same meaning as in the Corporations Act 2001.\nsuper-agent has the meaning given by subsection 4-13(2).\ntracing information, in relation to a transfer of value, means information that\nsatisfies both of the following:\n(a) the information:\n(i) for a transfer from an"}, {"chunk_id": "c4a92930a8caf822::57d::3f76", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 28, "passage": "Part 4-Registration\nDivision 1-Management of the Remittance Sector Register and the\nVirtual Asset Service Provider Register\n4-1 Correction of entries\n(1) This section is made for the purposes of paragraphs 75(4)(a) and 76B(4)(a) of the\nAct. (2) If the AUSTRAC CEO reasonably believes that there is an error in, or omission\nfrom, an entry in the Remittance Sector Register or the Virtual Asset Service\nProvider Register, the AUSTRAC CEO may correct the error or omission. (3) As soon as reasonably practicable after making a correction of an entry under\nthis section, the AUSTRAC CEO must give notice of the correction to:\n(a) the person whose registration the entry relates to; and\n(b) if the registration is of a person as a remittance affiliate of a registered\nremittance network provider-the provider.\n4-2 Publication of register information\n(1) For the purposes of subsections 75(4) and 76B(4) of the Act, the AUSTRAC\nCEO must publish the following on AUSTRAC's website:\n(a) the details mentioned in paragraphs 75A(1)(a), (b), (c) and (f) of the Act on\nthe Remittance Sector Register;\n(b) the details mentioned in paragraphs 76C(a) and (d) of the Act on the\nVirtual Asset Service Provider Register;\n(c) information mentioned in section 4-24 of this instrument (register entry in\nrelation to suspension of registration) on the Remittance Sector Register\nand the Virtual Asset Service Provider Register."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The regimes regulate distinct aspects of the financial system. Regime A (AU_TRAVEL_RULE) focuses on Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations for remittance and virtual asset service providers, specifically regarding customer identification and reporting (c4a92930a8caf822::380::0a18, c4a92930a8caf822::57d::3f76). Regime B (INT_BASEL_CRYPTO) focuses on prudential capital requirements and risk-weighting for banks' exposures to financial institutions (32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). There is no specific obligation in Regime A that pushes against a specific obligation in Regime B; rather, they apply in different domains (AML/CTF vs. Capital Adequacy)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-18T11:48:14Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.75, "record_type": "conflict", "pair_id": "conflict:19b4e52674bf0c1e5488d568", "label": "conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_AFSL"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "evidence_a": [{"chunk_id": "e3809bb1f352508e::38a::ddd7", "source_doc": "Guidelines_Reverse_Solicitation_MiCA.pdf", "page": 14, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}, {"chunk_id": "25cbbd878a1b21d3::38a::ddd7", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 47, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}], "evidence_b": [{"chunk_id": "8885979388bc0a29::52c::d4fe", "source_doc": "RG_1_Applying_for_AFS_Licence.pdf", "page": 38, "passage": "RG 1.187 AFS licensees have obligations under s912A requiring them to:\n(a) operate their business efficiently, honestly and fairly;\n(b) maintain the organisational competence to provide the financial services\ncovered by their licence;\n(c) ensure their representatives are competent and adequately trained to\nprovide the financial services;\n(d) have adequate financial, technological and human resources to provide\nthe financial services;\n(e) have risk management systems;\n(f) have arrangements in place for managing conflicts of interest;\n(g) comply with the financial services laws and ensure their representatives\ncomply with those laws;\n(h) comply with the conditions on their licence; and\n(i) if they are the operator of an Australian passport fund or a person with\nresponsibilities in relation to an Australian passport fund-comply with\nthe law of each host economy for the fund.\nNote 1: If you are an eligible body under ASIC Corporations (Foreign Financial Services\nProviders-Foreign AFS Licensees) Instrument 2020/198 you may be exempt from some\nof these obligations.\nNote 2: If you are providing financial services to retail clients, you will have additional\ndispute resolution and compensation obligations. Please see s912B for more information.\n© Australian Securities and Investments Commission June 2025 Page 38"}, {"chunk_id": "8885979388bc0a29::28c::e3b4", "source_doc": "RG_1_Applying_for_AFS_Licence.pdf", "page": 39, "passage": "RG 1.193 If we grant you an AFS licence, your licensee obligations include your\nstatutory obligations including those in s912A, the licence conditions imposed\nunder the Corporations Regulations including reg 7.6.04, and the licence\nconditions imposed by ASIC in PF 209, as well as any tailored licence\nconditions that apply specifically to you.\n© Australian Securities and Investments Commission June 2025 Page 39\n\nEfficiently, honestly and fairly\n\nRG 1.194 Section 912A(1)(a) requires that a financial services licensee do all things\nnecessary to ensure that the financial services covered by the licence are\nprovided efficiently, honestly and fairly."}], "rationale": "EU_MICA (EU's broad crypto-asset regulation) and AU_ASIC_AFSL (AU AFSL framework, extended to crypto-as-financial-product per ASIC INFO 225). Whether AU AFSL applies to a given crypto activity turns on FACTS about the underlying crypto-asset's characteristics (whether it is a financial product). The combined regulatory burden on an entity operating in both jurisdictions depends on that fact-sensitive determination.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:28:02Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:e0d891d4f66d8acdade4ea10", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "Market Abuse Regulation"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title V (CASP)"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::1bd::d04c", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 14\nProhibition of insider dealing and of unlawful disclosure of inside information\nA person shall not:\n(a) engage or attempt to engage in insider dealing;\n(b) recommend that another person engage in insider dealing or induce another person to engage in insider dealing; or\n(c) unlawfully disclose inside information.\n\nArticle 15\nProhibition of market manipulation\nA person shall not engage in or attempt to engage in market manipulation."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::eb::35e6", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 59\nAuthorisation\n1.\nA person shall not provide crypto-asset services, within the Union, unless that person is:\n(a) a legal person or other undertaking that has been authorised as crypto-asset service provider in accordance with"}, {"chunk_id": "491a2f0014d56ffb::452::8eaf", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 63; or\n(b) a credit institution, central securities depository, investment firm, market operator, electronic money institution,\nUCITS management company, or an alternative investment fund manager that is allowed to provide crypto-asset\nservices pursuant to Article 60. EN\nL 150/114 2. Crypto-asset service providers authorised in accordance with Article 63 shall have a registered office in a Member\nState where they carry out at least part of their crypto-asset services. They shall have their place of effective management\nin the Union and at least one of the directors shall be resident in the Union.\n3. For the purposes of paragraph 1, point (a), other undertakings that are not legal persons shall only provide crypto-\nasset services if their legal form ensures a level of protection for third parties' interests equivalent to that afforded by\nlegal persons and if they are subject to equivalent prudential supervision appropriate to their legal form.\n4. Crypto-asset service providers authorised in accordance with Article 63 shall at all times meet the conditions for\ntheir authorisation.\n5."}], "rationale": "MiCA Title VI explicitly imports a MAR-style market-abuse regime for crypto-assets admitted to trading on EU venues. The two regimes are designed to coexist with MiCA providing the crypto-specific market-abuse rules and MAR remaining the lex generalis for financial-instrument market abuse. Hard negative.", "would_conflict_if": ["A crypto-asset that is also a financial instrument under MiFID II — that's a classification question handled by ESMA Guidelines on Qualification of CAs as FIs."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:14:27Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:04dd1315c3d5c0a856a518cf", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "rationale": "The evidence for Regime A (AU_FEDREG_AML) focuses on Anti-Money Laundering (AML) obligations, customer identification, and reporting requirements for reporting entities. The evidence for Regime B (EU_EMD2) concerns Digital Operational Resilience for the financial sector (DORA) and financial rules for the Authority. The passages describe distinct regulatory domains (AML compliance vs. operational resilience and financial administration) with no overlapping obligations or conflicting requirements. Therefore, the regimes do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:f7d3e2333839d2eccf3e7622", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "ESMA-Guidelines", "short_name": "ESMA Reverse Solicitation Guidelines"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "evidence_b": [{"chunk_id": "e3809bb1f352508e::1e2::5805", "source_doc": "Guidelines_Reverse_Solicitation_MiCA.pdf", "page": 10, "passage": "25. The reverse solicitation exemption is based on the premise that the crypto-asset product,\nservice or activity is provided at the client's own exclusive initiative. Article 61(2) of MiCA\nleaves open the possibility for the third-country firm to market to that client crypto-assets\nor crypto-asset services or activities of the same type. However, the requirement that the\ncrypto-asset services be provided on the basis of the own exclusive initiative of the client\nstill applies."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLD 6 AML supervisory directive and ESMA's reverse-solicitation Guidelines under MiCA operate in disjoint regulatory domains at the obligation level. AML supervisory directive vs MiCA reverse-solicitation guidelines — different subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:13:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:550d63c22d8bd8cc725dc832", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}, {"chunk_id": "28dfda0f6a6539b6::4f2::95d6", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Such a warning may be\nprovided in a standardised format;\n(d) the investment firm complies with its obligations under Article 23.\n5. The investment firm shall establish a record that includes the document or documents agreed between the\ninvestment firm and the client that set out the rights and obligations of the parties, and the other terms on which\nthe investment firm will provide services to the client. The rights and duties of the parties to the contract may be\nincorporated by reference to other documents or legal texts.\n6. The investment firm shall provide the client with adequate reports on the service provided in a durable medium. Those reports shall include periodic communications to clients, taking into account the type and the complexity of\nfinancial instruments involved and the nature of the service provided to the client and shall include, where applicable, the\ncosts associated with the transactions and services undertaken on behalf of the client. When providing investment advice, the investment firm shall, before the transaction is made, provide the client with a\nstatement on suitability in a durable medium specifying the advice given and how that advice meets the preferences,\nobjectives and other characteristics of the retail client."}, {"chunk_id": "28dfda0f6a6539b6::514::0ca0", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 57, "passage": "Article 24\nGeneral principles and information to clients\n1. Member States shall require that, when providing investment services or, where appropriate, ancillary services to\nclients, an investment firm act honestly, fairly and professionally in accordance with the best interests of its clients and\ncomply, in particular, with the principles set out in this Article and in Article 25.\n2. Investment firms which manufacture financial instruments for sale to clients shall ensure that those financial\ninstruments are designed to meet the needs of an identified target market of end clients within the relevant category\nof clients, the strategy for distribution of the financial instruments is compatible with the identified target market, and the\ninvestment firm takes reasonable steps to ensure that the financial instrument is distributed to the identified target\nmarket. An investment firm shall understand the financial instruments they offer or recommend, assess the compatibility of the\nfinancial instruments with the needs of the clients to whom it provides investment services, also taking account of the\nidentified target market of end clients as referred to in Article 16(3), and ensure that financial instruments are offered or\nrecommended only when this is in the interest of the client.\n3."}, {"chunk_id": "28dfda0f6a6539b6::52e::014d", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 57, "passage": "All information, including marketing communications, addressed by the investment firm to clients or potential\nclients shall be fair, clear and not misleading. Marketing communications shall be clearly identifiable as such.\n4. Appropriate information shall be provided in good time to clients or potential clients with regard to the investment\nfirm and its services, the financial instruments and proposed investment strategies, execution venues and all costs and\nrelated charges. That information shall include the following:\n(a) when investment advice is provided, the investment firm must, in good time before it provides investment advice,\ninform the client:\n(i) whether or not the advice is provided on an independent basis;\n(ii) whether the advice is based on a broad or on a more restricted analysis of different types of financial instruments\nand, in particular, whether the range is limited to financial instruments issued or provided by entities having close\nlinks with the investment firm or any other legal or economic relationships, such as contractual relationships, so\nclose as to pose a risk of impairing the independent basis of the advice provided;\n(iii) whether the investment firm will provide the client with a periodic assessment of the suitability of the financial\ninstruments recommended to that client;"}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "75b61beed88910f9::4ad::debc", "source_doc": "National_ML_TF_Risk_Assessment.pdf.coredownload.inline.pdf", "page": null, "passage": "The guidance contained in this document takes into consideration previous FATF work , which is still valid reference material. The general\nprinciples contained in this paper are also relevant when conducting risk assessments of a more\nfocussed scope, such as in assessments of a particular financial or DNFBP sector (for example, the\nsecurities sector) or of thematic issues (for example, the proceeds of corruption related ML). All of\nthese types of assessments (comprehensive, sectoral or thematic) carried out at the national level\nmay also form the basis for determining whether to apply enhanced or specific measures, simplified\nmeasures, or exemptions from AML/CFT requirements. Furthermore, while FATF\nRecommendation 1 does not create specific risk assessment obligations regarding the financing of\nproliferation of weapons of mass destruction, the general principles laid out in this guidance could\nalso be used in conducting a risk assessment for this area.\n3. The guidance in this document is not intended to explain how supervisors should assess risks\nin the context of risk-based supervision, although risk-based supervision will likely be informed by a\nnational-level risk assessment."}, {"chunk_id": "1393876621ff1b2d::215::b185", "source_doc": "Guidance-Criminalising-Terrorist-Financing.pdf.coredownload.inline.pdf", "page": 3, "passage": "4. This guidance is based on the same general principles that govern both the interpretation and\nassessment of the FATF standards. As noted in the introduction to the 2012 FATF\n\"Countries have diverse legal, administrative and operational frameworks and different\nRecommendations:\nfinancial systems, and so cannot all take identical measures to counter these threats. The FATF\nRecommendations, therefore, set an international standard, which countries should implement\nthrough measures adapted to their particular circumstances.\"\nhow"}, {"chunk_id": "601316b5944a8a71::49b::b6c2", "source_doc": "Terrorist-Financing-Risk-Assessment-Guidance.pdf.coredownload.pdf", "page": 35, "passage": "Box 3.1. Potential Use of Financial Intelligence to Assess Cross-border TF\nRisks\nCross-border transaction or movement reports (CTRs) - The FATF\nStandards require that all countries implement a declaration or disclosure\nsystem for incoming and outgoing cross-border transportation of currency\nand bearer negotiable instruments (CBNIs) with a maximum threshold of\nUSD/EUR 15 000 (FATF Recommendation 32.) While the low volume of\nfunds often used by terrorists presents challenges for detection in a\nthreshold-based system, countries to date have found that information on\n40 Notably, chapter 2 above also contains guidance and information sources relevant when assessing\ncross-border TF risks. 34 │ TERRORIST FINANCING RISK ASSESSMENT GUIDANCE\nthe general inflows/outflows of CBNI may still provide useful information\non the potential TF vulnerabilities posed by different borders. Suspicious Transaction Reports (STRs) - The FATF Standards require\nthat all financial institutions and DNFBPs should be required to notify the\nFIU if they suspect or have reasonable grounds to suspect that funds are the\nproceeds of a criminal activity, or are related to TF (FATF Recommendation\n20)."}, {"chunk_id": "08b3db1cc7362f25::3bb::5dba", "source_doc": "Guidance-Correspondent-Banking-Services.pdf.coredownload.pdf", "page": null, "passage": "FATF GUIDANCE\nCORRESPONDENT\nBANKING SERVICES\nOCTOBER 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on correspondent banking services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/correspondent-banking-services.html\n© 2016 FATF/OECD."}], "rationale": "The EU MIFID2 passages regulate the conduct of investment firms, specifically regarding product governance, suitability assessments, and client information disclosure (e.g., Article 1, Article 24, Article 25). The INT_FATF_GENERAL passages provide high-level guidance on assessing money laundering and terrorist financing (ML/TF) risks and the general principles of the FATF Recommendations. The obligations in MIFID2 relate to the suitability and quality of financial advice for clients, while the FATF passages relate to national risk assessments and reporting suspicious transactions. There is no specific obligation in MIFID2 that conflicts with a specific obligation in the FATF guidance; rather, they regulate distinct domains of financial regulation. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:46:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:6c7a7a217c202008fca537bd", "label": "conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title IV (EMT)"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + TFR"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::321::0923", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 74, "passage": "Article 57\nVoluntary classification of e-money tokens as significant e-money tokens\n1.\nAn issuer of an e-money token, authorised as a credit institution or as an electronic money institution, or applying\nfor such authorisation, may indicate that it wishes for its e-money token to be classified as a significant e-money token.\nIn that case, the competent authority shall immediately notify such request of the issuer to EBA, to the ECB and, in the\ncases referred to in Article 56(3), second subparagraph, to the central bank of the Member State concerned.\nIn order for the e-money token to be classified as significant under this Article, the issuer of the e-money token shall\ndemonstrate, through a detailed programme of operations, that it is likely to meet at least three of the criteria set out in"}, {"chunk_id": "491a2f0014d56ffb::53d::70f2", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 13, "passage": "(66)\nIssuers of e-money tokens should be authorised either as a credit institution under Directive 2013/36/EU or as an\nelectronic money institution under Directive 2009/110/EC. E-money tokens should be deemed to be 'electronic\nmoney' as that term is defined in Directive 2009/110/EC and their issuers should, unless specified otherwise in\nthis Regulation, comply with the relevant requirements set out in Directive 2009/110/EC for the taking up,\npursuit and prudential supervision of the business of electronic money institutions and the requirements on\nissuance and redeemability of e-money tokens. Issuers of e-money tokens should draw up a crypto-asset white\npaper and notify it to their competent authority. Exemptions regarding limited networks, regarding certain\ntransactions by providers of electronic communications networks and regarding electronic money institutions\nissuing only a limited maximum amount of electronic money, based on the optional exemptions specified in\nDirective 2009/110/EC, should also apply to e-money tokens. However, issuers of e-money tokens should still be\nrequired to draw up a crypto-asset white paper in order to inform buyers about the characteristics and risks of\nthe e-money tokens and should also be required to notify the crypto-asset white paper to the competent authority\nbefore its publication."}], "evidence_b": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}, {"chunk_id": "d7502c011527b67c::1a0::faa6", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 24, "passage": "Article 19\nRetention of information on the originator and the beneficiary accompanying the transfer\nIntermediary crypto-asset service providers shall ensure that all the information received on the originator and the\nbeneficiary that accompanies a transfer of crypto-assets is transmitted with the transfer and that records of such\ninformation are retained and made available on request to the competent authorities."}, {"chunk_id": "d7502c011527b67c::743::1b5f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 23, "passage": "Article 16\nDetection of missing information on the originator or the beneficiary\n1.\nThe crypto-asset service provider of the beneficiary shall implement effective procedures, including, where appro\npriate, monitoring after or during the transfers, in order to detect whether the information referred to in Article 14(1)\nand (2) on the originator and the beneficiary is included in, or follows, the transfer or batch file transfer of crypto-assets.\n2.\nIn the case of a transfer of crypto-assets made from a self-hosted address, the crypto-asset service provider of the\nbeneficiary shall obtain and hold the information referred to in Article 14(1) and (2) and shall ensure that the transfer of\ncrypto-assets can be individually identified.\nWithout prejudice to specific risk mitigating measures taken in accordance with Article 19b of Directive (EU) 2015/849,\nin the case of a transfer of an amount exceeding EUR 1 000 from a self-hosted address, the crypto-asset service provider\nof the beneficiary shall take adequate measures to assess whether that address is owned or controlled by the beneficiary.\n3.\nBefore making the crypto-assets available to the beneficiary, the crypto-asset service provider of the beneficiary\nshall verify the accuracy of the information on the beneficiary referred to in Article 14(2) on the basis of documents,\ndata or information obtained from a reliable and independent source.\n4.\nVerification as referred to in paragraphs 2 and 3 of this Article shall be deemed to have taken place where one of\nthe following applies:\n(a) the identity of the beneficiary has been verified in accordance with Article 13 of Directive (EU) 2015/849 and the\ninformation obtained pursuant to that verification has been retained in accordance with Article 40 of that Directive;\n(b) Article 14(5) of Directive (EU) 2015/849 applies to the beneficiary."}], "rationale": "An EMT issuer authorised under MiCA Title IV (and therefore operating as a credit institution or electronic money institution under EMD2 / CRD IV) becomes simultaneously subject to the TFR travel-rule regime when it provides crypto-asset transfer services or when EMT transfers occur through CASPs. MiCA Title IV imposes white-paper, reserve and redemption-at-par obligations; the TFR overlays an originator / beneficiary information, retention and detection duty on top. The tension is operational rather than structural: both regimes apply, neither blocks the other, but the EMT issuer must layer in TFR-grade KYC and transmission infrastructure on top of its MiCA Title IV compliance stack — at meaningful cost. This is operationally resolvable through a single integrated CDD + transmission design.", "compliant_paths": ["Build a unified CDD + transmission layer that satisfies both MiCA Art. 49 redemption-at-par customer-identification needs and TFR Art. 14 transmission fields.", "Use TFR Art. 16 risk-based procedures for detection of missing information at the EMT-distribution boundary."], "out_of_scope_assumptions": ["EMT issuer also acts as CASP for distribution; if distribution is exclusively through external CASPs, the TFR duty sits primarily on those CASPs."]}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.86, "record_type": "non_conflict", "pair_id": "non_conflict:843831e85e2d24c968ea1343", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "GDPR"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85307f9e2a040982::7ba::5889", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 32, "passage": "27.12.2022 EN Official Journal of the European Union L 333/33\n(d) ensure that data is protected from risks arising from data management, including poor administration, processing-\nrelated risks and human error.\n4. As part of the ICT risk management framework referred to in Article 6(1), financial entities shall:\n(a) develop and document an information security policy defining rules to protect the availability, authenticity, integrity\nand confidentiality of data, information assets and ICT assets, including those of their customers, where applicable;\n(b) following a risk-based approach, establish a sound network and infrastructure management structure using appropriate\ntechniques, methods and protocols that may include implementing automated mechanisms to isolate affected\ninformation assets in the event of cyber-attacks;\n(c) implement policies that limit the physical or logical access to information assets and ICT assets to what is required for\nlegitimate and approved functions and activities only, and establish to that end a set of policies, procedures and\ncontrols that address access rights and ensure a sound administration thereof;\n(d) implement policies and protocols for strong authentication mechanisms, based on relevant standards and dedicated\ncontrol systems, and protection measures of cryptographic keys whereby data is encrypted based on results of\napproved data classification and ICT risk assessment processes;\n(e) implement documented policies, procedures and controls for ICT change management, including changes to software,\nhardware, firmware components, systems or security parameters, that are based on a risk assessment approach and are\nan integral part of the financial entity's overall change management process, in order to ensure that all changes to ICT\nsystems are recorded, tested, assessed, approved, implemented and verified in a controlled manner;\n(f) have appropriate and comprehensive documented policies for patches and updates."}, {"chunk_id": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}], "evidence_b": [{"chunk_id": "bd84e63f5b622b73::5e9::a119", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 48, "passage": "Article 25\nData protection by design and by default\n1. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of\nprocessing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the\nprocessing, the controller shall, both at the time of the determination of the means for processing and at the time of the\nprocessing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are\ndesigned to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the\nnecessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of\ndata subjects.\n2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default,\nonly personal data which are necessary for each specific purpose of the processing are processed. That obligation applies\nto the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility.\nIn particular, such measures shall ensure that by default personal data are not made accessible without the individual's\nintervention to an indefinite number of natural persons.\n3. An approved certification mechanism pursuant to Article 42 may be used as an element to demonstrate\ncompliance with the requirements set out in paragraphs 1 and 2 of this Article."}, {"chunk_id": "bd84e63f5b622b73::4cb::2d6b", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 1, "passage": "In order to be able to demonstrate compliance with this Regulation, the controller should\nadopt internal policies and implement measures which meet in particular the principles of data protection by\ndesign and data protection by default. Such measures could consist, inter alia, of minimising the processing of\npersonal data, pseudonymising personal data as soon as possible, transparency with regard to the functions and\nprocessing of personal data, enabling the data subject to monitor the data processing, enabling the controller to\ncreate and improve security features. When developing, designing, selecting and using applications, services and\nproducts that are based on the processing of personal data or process personal data to fulfil their task, producers\nof the products, services and applications should be encouraged to take into account the right to data protection\nwhen developing and designing such products, services and applications and, with due regard to the state of the\nart, to make sure that controllers and processors are able to fulfil their data protection obligations. The principles\nof data protection by design and by default should also be taken into consideration in the context of public\ntenders."}], "rationale": "DORA's information-security policy obligation (Art. 9) expressly requires the protection of the availability, authenticity, integrity and confidentiality of data and explicitly references data-protection considerations. GDPR Article 25 imposes data protection by design and by default. The two regimes reinforce rather than oppose: DORA tells regulated firms to invest in ICT security capabilities; GDPR Art. 25 tells them to make those capabilities serve data-protection ends. Where breach reporting is concerned (DORA Art. 17–18 ICT incident reporting vs GDPR Art. 33 breach notification), the obligations are cumulative — the same incident may trigger both reporting channels, which is a coordination cost but not a conflict.", "would_conflict_if": ["DORA mandated retention of full ICT logs beyond a period GDPR allows for personal-data minimisation; current text avoids this by limiting log retention to what is necessary for the ICT-risk purpose."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:27:39Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:ca77f445da5938bf37b4b3ea", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "0fc4f857c226f510::375::66b5", "source_doc": "Corporations_Act_2001_Vol1.pdf", "page": 296, "passage": "Part 1.6 Interaction with Australian Charities and Not-for-profits Commission Act Section 111L\nProvisions of this Act that do not apply to bodies corporate registered under the\nACNC Act\nItem Column 1 Column 2\nProvision(s) Topic\n2 section 138 ASIC may direct company to lodge\nconsolidated constitution\n3 section 139 Company must send copy of\nconstitution to member\n4 subsection 142(2), section 146 and Company must notify ASIC of\nsubsection 146A(2) changes of address\n5 (a) sections 180 to 183; and Duties of directors etc. (b) section 185, to the extent that it\nrelates to sections 180 to 183\n6 section 188, to the extent it relates to Responsibility of secretaries and\na provision mentioned in another directors for certain contraventions\nitem of this table\n7 sections 191 to 194 Interests of directors\n8 (a) sections 201L and 205A to 205C; Public information about directors\nand etc."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The evidence from the Australian Corporations Act (Regime A) focuses on the interaction with the Australian Charities and Not-for-profits Commission Act, detailing specific provisions regarding company constitutions, director duties, and winding up (chunk 0fc4f857c226f510::375::66b5). The evidence from the International Organization of Securities Commissions (Regime B) outlines the IOSCO Principles and their role as key standards for securities regulation, emphasizing cooperation and the establishment of standards for financial systems (chunk f173909614befd49::455::1a1a). The obligations in Regime A relate to corporate governance and statutory compliance for bodies corporate, while Regime B provides international methodological guidance and principles for securities regulation. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B; rather, they operate in different domains (corporate governance vs. international securities standards)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b6a4554190ed9356d2299a61", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::361::e378", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 16, "passage": "57. ESMA is mandated in Article 84(4) of MiCA to develop, in close cooperation with EBA,\ndraft regulatory technical standards (RTS) on the detailed content of the information for\nthe assessment of proposed acquisitions of qualifying holdings in CASPs. The aim of\nthis draft RTS is to specify the detailed content of the information that direct or indirect\nproposed acquirers must provide to national competent authorities (NCAs) when\nnotifying the intended acquisition. This should ensure a harmonised approach to the\nassessment across Member States in the EU of the intended acquisition of qualifying\nholdings in CASPs.\n\n58. The RTSs are applicable to proposed acquirers of qualifying holdings in CASPs, as well\nas NCAs as designated under Article 93(1) of MiCA that will conduct the assessment of\nthe intended acquisition in accordance with Article 83(4) of MiCA."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}], "rationale": "EU_MICA_RTS (EU MiCA regulatory technical standards) and EU_MICA_TITLE_V_CASP (EU MiCA Title V CASP authorisation). Both are parts of the same MiCA framework — Title V establishes the CASP authorisation regime; the RTS provide detailed technical specifications. Aligned by design."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:31:53Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:8dda84db1c6d85bde8b5bd6f", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "The evidence from the Australian regime (AU_ATO_CRYPTO) focuses on token mapping, tax compliance, and general crypto adoption statistics (chunk_id e6bb47e92e88e16c::567::36c4). The evidence from the Singaporean regime (SG_PSA_DPT) outlines the licensing requirements and AML/CFT obligations for Digital Payment Token (DPT) service providers under the Payment Services Act (chunk_id 4b4c3c417dc293ba::185::f41d). While both regimes regulate the crypto sector, the specific obligations cited—tax reporting and AML/CFT licensing—are distinct domains. There is no evidence of a specific obligation in one regime directly conflicting with a specific obligation in the other. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:43:00Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b19833d6f9ff4b0317226f2a", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::41f::546c", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 24, "passage": "3.1 Standard AFSL Obligations\nAustralian financial services licence\n(a) A platform provider must hold an AFSL authorising them to issue and deal in digital asset facilities.\n(b) A platform provider is exempt from holding an AFSL for digital asset facilities if:\n(i) the total value of platform entitlements held by any one client of the platform provider does\nnot exceed $1,500 at any one time; and\n(ii) the total amount of assets held by the platform provider does not exceed $5 million at any\ntime.\nInfo Box 3 Low value exemption\nThe risks with digital asset facilities are correlated to the size and scale of the asset holding role of\nthe platform provider. Accordingly, a 'low-value facility' exemption would be introduced, similar to\nthe 'low value facility' exemption for non-cash payment facilities. It would apply to digital asset\nfacilities holding less than $1,500 per customer and less than $5 million in total.40 This exemption\nis intended to allow for innovation and experimentation in the early stages of developing a novel\nservice offering."}, {"chunk_id": "550958b067dc6726::709::b159", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 15, "passage": "2.3 Overview of proposed framework\nLicensing\nThe proposed framework would recognise certain asset holding arrangements as a financial product (a\ndigital asset facility). The existing AFSL framework would apply to any person 'carrying on a financial\nservices business in Australia' in relation to a digital asset facility. Examples of 'financial services'\ninclude:\n• dealing in a financial product (including applying for or acquiring, issuing, varying or disposing of a\nfinancial product)\n• making a market for a financial product\n• providing a custodial or depository service, and\n• providing financial product advice.\nThe issuer of a digital asset facility would be the person or persons responsible for the obligations\nowed to customers under the terms of the asset holding arrangement (platform provider). Platform\nproviders and other intermediaries performing financial services in relation to digital asset facilities\n(e.g. brokers, arrangers, agents, market makers, and advisers) would be required to hold an AFSL.\nWhile the application of the AFSL regime would be jurisdictionally limited to Australia in the usual way,\nan intermediary business in Australia, like a broker, would need to be licensed to provide services that\ninvolve dealing in digital asset facilities generally (including those not licensed or located in Australia).\nSee Part 3 for further detail about licensing obligations.\nFacility contracts\nThe proposed framework would permit digital asset facilities to be paired with other functions,\ncreating digital asset platforms. All arrangements involving digital asset facilities would be required to\nbe structured as non-discretionary arrangements.29 The term 'non-discretionary' means the\narrangements must operate according to pre-agreed and transparent rules and procedures."}], "evidence_b": [{"chunk_id": "20d526d712753652::3ee::1555", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Harmonizing compliance standards for both financial institutions and payment\nservice providers is the best way to combat the global rise in money laundering,\nterrorism financing, and sanctions evasion, to plug gaps in overseeing transfers of\nvalue. Preventing SG-licensed entities from relying on foreign-licensed institutions 30 May 2025 | 40\nwith only money-transmitter-type licenses would be a useful step towards those\nlarger goals. Question 7. Reliance on Third Party. MAS seeks comments on the proposed amendments to\nthe other AML/CFT notices. No comment. Question 8. Correspondent Account Services. MAS seeks comments on whether the proposed\nrequirements for Correspondent Account Services set out in paragraph 5.6 would\nbe applicable to the sector. (Please refer to paragraph 12 of the draft FSM Notice). For correspondent account services, the licensee is relying on their client's standard\nof compliance in a manner similar to the \"Reliance on Third Party\" issues discussed\nin previous questions."}, {"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "The Australian regime (AU_ASIC_AFSL) regulates the licensing and conduct of financial services providers, specifically digital asset facilities and intermediaries, focusing on financial product definitions, AFSL requirements, and financial resources. The Singaporean regime (SG_MAS_AML_GENERAL) focuses on Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) obligations, specifically regarding targeted financial sanctions, the role of the compliance function, and the supervision of Digital Payment Token (DPT) providers. The obligations in Regime A (licensing and financial requirements) do not directly oppose or conflict with the obligations in Regime B (AML/CFT compliance and sanctions), but rather apply to different aspects of the same entity's operations. The Singaporean text explicitly mentions that entities operating under a transitional exemption are not licensed under the Payment Services Act but are allowed to continue providing services, indicating a regulatory pathway that accommodates the licensing requirements of other regimes like AFSL."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:59:47Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:1f17e6830cc1f09388876267", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The EU_MAR regime regulates market integrity, specifically insider dealing and market manipulation (chunks 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The INT_BASEL_CRYPTO regime regulates capital adequacy and prudential standards for banks (chunks 32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). The obligations in MAR relate to the conduct of trading and reporting suspicious activity, while the obligations in Basel relate to the calculation of capital requirements and risk weighting of exposures. These are distinct regulatory domains; compliance with one does not impede compliance with the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:42:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b7929394be2f372f8d5e87bf", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "evidence_b": [{"chunk_id": "20d526d712753652::3ee::1555", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Harmonizing compliance standards for both financial institutions and payment\nservice providers is the best way to combat the global rise in money laundering,\nterrorism financing, and sanctions evasion, to plug gaps in overseeing transfers of\nvalue. Preventing SG-licensed entities from relying on foreign-licensed institutions 30 May 2025 | 40\nwith only money-transmitter-type licenses would be a useful step towards those\nlarger goals. Question 7. Reliance on Third Party. MAS seeks comments on the proposed amendments to\nthe other AML/CFT notices. No comment. Question 8. Correspondent Account Services. MAS seeks comments on whether the proposed\nrequirements for Correspondent Account Services set out in paragraph 5.6 would\nbe applicable to the sector. (Please refer to paragraph 12 of the draft FSM Notice). For correspondent account services, the licensee is relying on their client's standard\nof compliance in a manner similar to the \"Reliance on Third Party\" issues discussed\nin previous questions."}, {"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "The EU DAC8 regime focuses on tax transparency and the automatic exchange of information regarding crypto-asset users with non-Union jurisdictions (chunk_ids c0300673081f7232::320::7b46, c0300673081f7232::498::163c). In contrast, the SG_MAS_AML_GENERAL regime addresses Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) obligations, licensing, and supervision of Digital Payment Token (DPT) service providers and financial institutions (chunk_ids 20d526d712753652::3ee::1555, b49627bb889ef1d9::1b6::0802). The obligations in DAC8 are administrative and tax-focused, while the obligations in MAS are regulatory and compliance-focused. There is no specific obligation in one regime that pushes against a specific obligation in the other; rather, they operate in different domains (tax vs. AML/CFT supervision)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:58:42Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:02baaa8f79fec77090315fe1", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "66d049e24f0863da::3f7::aec8", "source_doc": "Superannuation-Reporting-Standards-RIS.pdf", "page": 1, "passage": "1 INTRODUCTION\nThis Regulation Impact Statement (RIS) addresses the Australian Prudential Regulation\nAuthority's (APRA's) proposed introduction of new reporting standards applying to trustees of\nregistrable superannuation entities (RSE licensees). APRA is the prudential regulator of the superannuation, banking and insurance industries. Its\nmission is to ensure that, under all reasonable circumstances, financial promises made by APRA-\nregulated institutions are met within a stable, efficient and competitive financial system. APRA\ncarries out this mission through a multi-layered prudential framework that encompasses\nlicensing and supervision of institutions. For many years, APRA has had the power to make\nprudential standards implementing this framework for the banking and insurance industries. APRA is also empowered to make reporting standards under the Financial Sector (Collection of\nData) Act 2001 (FSCODA), which require regulated institutions to submit specified data through\nvarious reporting forms."}], "evidence_b": [{"chunk_id": "363e42358ddfaad9::36d::b55c", "source_doc": "FinalReport_MiCA_Cooperation_Technical_Standards.pdf", "page": 20, "passage": "(ii) all versions of the crypto-asset white paper referred to in Article 48(7) of Regulation\n(EU) 2023/1114;\n(iii) all versions of the marketing communications referred to in Article 53 of Regulation (EU)\n2023/1114;\n(iv) information about the organisational structure, operational conditions and compliance\nwith the requirements set out in Title IV of Regulation (EU) 2023/1114 of the issuer of\nthe e-money token and information provided as part of the authorisation process as\ncredit institution pursuant to Directive 2013/36/EU of the European Parliament and of\nthe Council13 or as electronic money institution pursuant to Directive 2009/110/EC of the\nEuropean Parliament and of the Council 14 and as updated in the framework of\nsupervision, including but not limited to:\n(1) its compliance with the requirements on the investment of funds set out in Article\n54 of Regulation"}], "rationale": "The evidence from APRA (Regime A) focuses on the prudential supervision of financial institutions, specifically the licensing and supervision of entities like ADIs and RSE licensees, and the issuance of legally binding prudential standards and reporting requirements (chunk_id 66d049e24f0863da::3f7::aec8). The evidence from MICA Title IV EMT (Regime B) focuses on the disclosure and authorisation requirements for issuers of e-money tokens and asset-referenced tokens, including the content of crypto-asset white papers and notification to competent authorities (chunk_id 363e42358ddfaad9::36d::b55c). The obligations in Regime A relate to the financial stability and capital adequacy of regulated financial institutions, while the obligations in Regime B relate to the transparency and consumer protection of crypto-asset issuers. These are distinct regulatory domains with no apparent overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:20:19Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:16f38442c1ec2ae34324d691", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "0fc4f857c226f510::375::66b5", "source_doc": "Corporations_Act_2001_Vol1.pdf", "page": 296, "passage": "Part 1.6 Interaction with Australian Charities and Not-for-profits Commission Act Section 111L\nProvisions of this Act that do not apply to bodies corporate registered under the\nACNC Act\nItem Column 1 Column 2\nProvision(s) Topic\n2 section 138 ASIC may direct company to lodge\nconsolidated constitution\n3 section 139 Company must send copy of\nconstitution to member\n4 subsection 142(2), section 146 and Company must notify ASIC of\nsubsection 146A(2) changes of address\n5 (a) sections 180 to 183; and Duties of directors etc. (b) section 185, to the extent that it\nrelates to sections 180 to 183\n6 section 188, to the extent it relates to Responsibility of secretaries and\na provision mentioned in another directors for certain contraventions\nitem of this table\n7 sections 191 to 194 Interests of directors\n8 (a) sections 201L and 205A to 205C; Public information about directors\nand etc."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "The evidence from the Australian Corporations Act passage (chunk 0fc4f857c226f510::375::66b5) outlines general corporate governance duties, such as the duties of directors and secretaries, and interaction with the ACNC Act. The evidence from the Singapore AML passage (chunk 3d521e61e49aaf46::38f::e615) outlines specific training obligations for direct life insurers regarding AML/CFT laws and suspicious transaction reporting. The obligations in the Singapore AML regime are specific to the prevention of money laundering and do not impose conflicting requirements on the general corporate governance duties detailed in the Australian Corporations Act. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:46:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:98fb796d34658539e2b87e7f", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + TFR"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiFID II"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}, {"chunk_id": "d7502c011527b67c::1a0::faa6", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 24, "passage": "Article 19\nRetention of information on the originator and the beneficiary accompanying the transfer\nIntermediary crypto-asset service providers shall ensure that all the information received on the originator and the\nbeneficiary that accompanies a transfer of crypto-assets is transmitted with the transfer and that records of such\ninformation are retained and made available on request to the competent authorities."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::49c::69f4", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 53, "passage": "Member States shall require that investment firms and market operators operating an MTF or an OTF establish,\npublish and maintain and implement transparent and non-discriminatory rules, based on objective criteria, governing\naccess to its facility.\n4. Member States shall require that investment firms and market operators operating an MTF or an OTF have\narrangements to identify clearly and manage the potential adverse consequences for the operation of the MTF or OTF,\nor for the members or participants and users, of any conflict of interest between the interest of the MTF, the OTF, their\nowners or the investment firm or market operator operating the MTF or OTF and the sound functioning of the MTF or\nOTF.\n5. Member States shall require that investment firms and market operators operating an MTF or OTF comply with\nArticles 48 and 49 and have in place all the necessary effective systems, procedures and arrangements to do so.\n6. Member States shall require that investment firms and market operators operating an MTF or an OTF clearly inform\nits members or participants of their respective responsibilities for the settlement of the transactions executed in that\nfacility."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "rationale": "AMLR/TFR addresses AML/CFT — customer due diligence, information accompanying transfers, retention. MiFID II addresses investment-firm authorisation and conduct — best execution, suitability, appropriateness, organisational requirements for trading venues. The two regimes apply to overlapping populations (an EU investment firm is both a MiFID-authorised firm and an obliged entity under AMLR), but the subject matters are disjoint at the obligation level. No AMLR/TFR obligation pushes against any MiFID II obligation. Hard negative — easy to mistake for a conflict because the regulated population overlaps.", "would_conflict_if": ["MiFID II suitability rules required disclosure to clients that AMLR confidentiality (tipping-off) rules prohibited — these regimes carve out the SMR / SAR confidentiality requirement separately."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:20:59Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:3ec526c243763583b880e0c1", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "08b3db1cc7362f25::3bb::5dba", "source_doc": "Guidance-Correspondent-Banking-Services.pdf.coredownload.pdf", "page": null, "passage": "FATF GUIDANCE\nCORRESPONDENT\nBANKING SERVICES\nOCTOBER 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on correspondent banking services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/correspondent-banking-services.html\n© 2016 FATF/OECD."}], "rationale": "The EU_PSD2 passages focus on technical security standards for payment transactions, specifically strong customer authentication (SCA) and the protection of personalised security credentials (chunk_ids: adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b). The INT_FATF_GENERAL passages focus on general principles for assessing money laundering and terrorist financing (ML/TF) risks and the implementation of AML/CFT standards (chunk_ids: fe52dd87e13dba41::261::59a4, 08b3db1cc7362f25::3bb::5dba). The obligations in PSD2 regarding authentication and security are complementary to, rather than in conflict with, the broader AML/CFT risk assessment and supervisory guidance provided by FATF. There is no specific obligation in PSD2 that pushes against a specific obligation in FATF."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:11:37Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f97a0b3e62393df73a7aec75", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}], "evidence_b": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "rationale": "The AU_TRAVEL_RULE passages discuss Australia's current status regarding the FATF 'Travel Rule' for digital currency exchanges, noting that it has not yet been implemented and that the regulatory framework currently only applies to exchanges between digital currency and fiat currency. In contrast, the EU_AMLA passages describe the overarching legal framework for AML/CFT obligations in the EU and the establishment of the AMLA authority. The regimes regulate different jurisdictions and the specific implementation status of the Travel Rule, with no evidence of a direct obligation in EU_AMLA that conflicts with the current or proposed obligations in AU_TRAVEL_RULE."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:46:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:2007abf8debba4fdab2bae2a", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4a92930a8caf822::380::0a18", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 12, "passage": "Part 1 Preliminary\nSection 1-4\n(a) in relation to registration or proposed registration of a person under Part 6\nof the Act as a remittance network provider-registrable remittance\nnetwork services; or\n(b) in relation to registration or proposed registration of a person under Part 6\nof the Act as an independent remittance dealer or a remittance affiliate of a\nregistered remittance network provider-registrable remittance services; or\n(c) in relation to registration or proposed registration of a person under Part 6A\nof the Act as a virtual asset service provider-registrable virtual asset\nservices.\nrelated body corporate has the same meaning as in the Corporations Act 2001.\nsuper-agent has the meaning given by subsection 4-13(2).\ntracing information, in relation to a transfer of value, means information that\nsatisfies both of the following:\n(a) the information:\n(i) for a transfer from an"}, {"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}, {"chunk_id": "33d059aa86716ddd::4ed::8511", "source_doc": "2022_CP_Stablecoin_Regulatory_Approach.pdf", "page": 6, "passage": "3.5 A wide range of stablecoins currently exist, varying in terms of their asset-\npegging, as well as the mechanism that upholds the stability of the stablecoins' value\nagainst the pegged asset(s). MAS intends to focus its regulatory regime on:\nSingle-currency pegged stablecoins (SCS) - As compared to other types of\nstablecoins (such as those pegged to a basket of currencies or other\nassets such as commodities), SCS has a stronger use case for payment and\nsettlement.\nNon-SCS will continue to be subject to the existing DPT regime under the\nPS Act. MAS views such stablecoins as being less stable in nominal value\nand should be treated differently from SCS.\nIn addition, even among SCS, there is variation in the stabilisation\nmechanism. MAS views stablecoins which are algorithmically-pegged,\nunbacked or backed by other cryptocurrencies to be more susceptible to\nvolatility in value. Correspondingly, such stablecoins will also continue to\nbe treated as DPTs.\nSCS issued in Singapore - The immediate priority of MAS is to elevate the\nstandard of SCS issued in Singapore. Our regulatory perimeter is thus\nscoped based on MAS' ability to directly impose requirements on the\nreserve management, redemption policies and prudential standards of\nthe SCS issuer."}], "rationale": "The AU Travel Rule passage discusses the Australian regulatory framework for digital currency exchanges and the potential implementation of FATF's Travel Rule to identify parties in transactions (chunk_ids c4a92930a8caf822::380::0a18, cf7cefacba3f94bc::383::7d9d). The SG Stablecoin passage outlines Singapore's regulatory perimeter for Single-Currency Stablecoins (SCS) issued in Singapore, distinguishing them from other digital payment tokens (chunk_ids 58f45cd2ef3de201::36c::e2f6, 33d059aa86716ddd::4ed::8511). The two regimes regulate distinct aspects of the digital asset ecosystem: one focuses on AML/CTF obligations and transaction identification for exchanges, while the other focuses on the issuance and reserve requirements of specific stablecoin products. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other. Therefore, the relationship is non_conflict with subtype different_domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:35:59Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:2e9ec7d671df701e0407c46a", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}], "rationale": "The evidence from Regime A (AU_FEDREG_AML) outlines obligations for reporting entities under the AML/CTF Act, including customer identification, suspicious transaction reporting, and program requirements. The evidence from Regime B (EU_MICA_TITLE_V_CASP) describes the requirements for authorisation as a Crypto-Asset Service Provider (CASP) under MiCA, specifically the application process and information requirements. The passages do not describe conflicting obligations; rather, they address distinct regulatory frameworks (financial crime prevention vs. crypto-asset service provider authorisation). Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T06:30:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.65, "record_type": "conflict", "pair_id": "conflict:a61f1c2ae14b454b3d155eb2", "label": "conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU AML/CTF Act + Rules"}, "regime_b": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU Privacy Act + APPs"}, "conflict_type": "recurring_friction", "severity": "medium", "evidence_a": [{"chunk_id": "254ca2d92d196180::369::b111", "source_doc": "Anti-Money Laundering act 2006.pdf", "page": 98, "passage": "Part 2 Identification procedures etc. Division 2 Identification procedures for certain pre-commencement customers\nSection 29\n(b) after the commencement of this section, a suspicious matter\nreporting obligation arises for the reporting entity in relation\nto the customer. Note 1: For suspicious matter reporting obligation, see section 41. Note 2: For tipping-off offences, see section 123. Requirement\n(2) The reporting entity must:\n(a) take such action as is specified in the AML/CTF Rules; and\n(b) do so within the time limit allowed under the AML/CTF\nRules. Civil penalty\n(3) Subsection (2) is a civil penalty provision. Interpretation\n(4) For the purposes of this section, assume that Part 1 had been in\nforce at all material times before the commencement of this\nsection.\n80 Anti-Money Laundering and Counter-Terrorism Financing Act 2006 Identification procedures etc."}, {"chunk_id": "50f54f147dcb1cba::30a::639e", "source_doc": "AML_CTF_Rules_2007.pdf", "page": 103, "passage": "Note: Where a reporting entity is unable to ascertain whether the circumstances in\n19.3(17)(a) applies, the reporting entity can assume that the transaction was\ncarried out by the customer.\n19.4 If the threshold transaction arises under a designated service that is of a kind\ndescribed in item 3 of table 1 in subsection 6(2) of the AML/CTF Act, the\nreference to 'customer' in subparagraphs 19.3(2) to 19.3(14) inclusive will\nbe taken, in the first instance, to refer only to the holder of the account and\nthe signatory (if any) conducting the transaction in relation to the account,\nprovided that:\n(1) if there are other signatories to the account, the AUSTRAC CEO may\nrequire the reporting entity to give to the AUSTRAC CEO, in the\nform of a supplement to the subsection 43(2)"}], "evidence_b": [{"chunk_id": "f9ea5fb6d86aeb75::6f0::32e8", "source_doc": "APP_Guidelines_Consolidated.pdf", "page": 4, "passage": "Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.3, October 2025\n8.27 The mechanism may be a single mechanism or a combination of mechanisms. It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\nException 2 - Disclosing personal information\nto an overseas recipient where the country or a\nbinding scheme is prescribed by regulations\n8.28 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where the overseas recipient of the relevant personal information is:\n• subject to the laws of a country prescribed by regulations, or a participant in a binding\nscheme prescribed by regulations,16 and\n• if the country or binding scheme is prescribed subject to conditions, those conditions are\nsatisfied.17\n8.29 Laws and binding schemes are discussed above at paragraphs 8.22-8.23.\n8.30 The Governor-General may make regulations under the Privacy Act to prescribe these\nmatters.18\nException 3 - Disclosing personal information\nto an overseas recipient with the individual's\nconsent after the individual is expressly\ninformed\n8.31 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))."}, {"chunk_id": "e9f6b0a9e797777d::634::e686", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Disclosing personal information to an overseas\nrecipient where a permitted general situation\nexists\n8.37 The cross-border principle will not apply if a permitted general situation exists for that\ndisclosure (APP 8.2(d)). Section 16A lists five permitted general situations that may exist for a\ncross border disclosure. These situations are set out below, and are discussed in more detail\nin Chapter C (Permitted general situations) (including the meaning of relevant terms).\n16 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 84. Office of the Australian Information Commissioner - APP Guidelines Page 11 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nLessening or preventing a serious threat to life, health or\nsafety\n8.38 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• it is unreasonable or impracticable to obtain the individual's consent to the disclosure,\nand\n• the entity reasonably believes the disclosure is necessary to lessen or prevent a serious\nthreat to the life, health or safety of any individual, or to public health or safety (s 16A(1),\nItem 1)\n8.39 For example, this permitted general situation might apply where an APP entity discloses the\npersonal information of an individual to a foreign authority, based on a reasonable belief\nthat this disclosure will lessen a serious threat to the health or safety of that individual's\nchildren, but seeking the individual's consent may increase the threat."}], "rationale": "The AML/CTF Act and Rules establish a seven-year retention regime for KYC, transaction and SMR records (sections 113–116 of the Act). APP 11.2 requires APP entities to take 'reasonable steps' to destroy or de-identify personal information that the entity 'no longer needs for any purpose' for which it may be used or disclosed under the APPs. The two settings push in opposite directions on a recurring basis: every customer departure resets a clock that ends with retention under AML/CTF (seven years post-relationship) but starts the APP 11.2 'reasonable steps to destroy' obligation in tension. The resolution is well-known (APP 11.2 has a 'unless required to retain by an Australian law' exception that AML/CTF satisfies), so this is not operationally unresolved; but the cost recurs and the periodic friction is real, particularly for entities with high customer churn or for SMRs that age past their statutory minimum.", "compliant_paths": ["Implement a retention-policy register that ties AML/CTF and APP 11.2 obligations to a single record-lifecycle calendar.", "After AML/CTF retention expires, destroy / de-identify per APP 11.2."], "out_of_scope_assumptions": ["Reporting entity has standardised customer onboarding documentation; bespoke or enhanced-CDD records may have different retention chains."]}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:50:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.72, "record_type": "conflict", "pair_id": "conflict:bcf57973323dfd9ec89fc1bd", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "GDPR"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title V (CASP)"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::4a6::7573", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 1, "passage": "Consistent and\nhomogenous application of the rules for the protection of the fundamental rights and freedoms of natural\npersons with regard to the processing of personal data should be ensured throughout the Union. Regarding the\nprocessing of personal data for compliance with a legal obligation, for the performance of a task carried out in\nthe public interest or in the exercise of official authority vested in the controller, Member States should be\nallowed to maintain or introduce national provisions to further specify the application of the rules of this\nRegulation. In conjunction with the general and horizontal law on data protection implementing Directive\n95/46/EC, Member States have several sector-specific laws in areas that need more specific provisions. This\nRegulation also provides a margin of manoeuvre for Member States to specify its rules, including for the\nprocessing of special categories of personal data ('sensitive data'). To that extent, this Regulation does not exclude\nMember State law that sets out the circumstances for specific processing situations, including determining more\nprecisely the conditions under which the processing of personal data is lawful."}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "bd84e63f5b622b73::5e9::a119", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 48, "passage": "Article 25\nData protection by design and by default\n1. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of\nprocessing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the\nprocessing, the controller shall, both at the time of the determination of the means for processing and at the time of the\nprocessing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are\ndesigned to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the\nnecessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of\ndata subjects.\n2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default,\nonly personal data which are necessary for each specific purpose of the processing are processed. That obligation applies\nto the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility.\nIn particular, such measures shall ensure that by default personal data are not made accessible without the individual's\nintervention to an indefinite number of natural persons.\n3. An approved certification mechanism pursuant to Article 42 may be used as an element to demonstrate\ncompliance with the requirements set out in paragraphs 1 and 2 of this Article."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::eb::35e6", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 59\nAuthorisation\n1.\nA person shall not provide crypto-asset services, within the Union, unless that person is:\n(a) a legal person or other undertaking that has been authorised as crypto-asset service provider in accordance with"}, {"chunk_id": "491a2f0014d56ffb::48f::be78", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 79, "passage": "Article 62\nApplication for authorisation as a crypto-asset service provider\n1.\nLegal persons or other undertakings that intend to provide crypto-asset services shall submit their application for\nan authorisation as a crypto-asset service provider to the competent authority of their home Member State.\n2.\nThe application referred to in paragraph 1 shall contain all of the following information:\n(a) the name, including the legal name and any other commercial name used, the legal entity identifier of the applicant\ncrypto-asset service provider, the website operated by that provider, a contact email address, a contact telephone\nnumber and its physical address;\nEN\nL 150/118\n\n(b) the legal form of the applicant crypto-asset service provider;\n(c) the articles of association of the applicant crypto-asset service provider, where applicable;\n(d) a programme of operations, setting out the types of crypto-asset services that the applicant crypto-asset service\nprovider intends to provide, including where and how those services are to be marketed;\n(e) proof that the applicant crypto-asset service provider meets the requirements for prudential safeguards set out in"}, {"chunk_id": "491a2f0014d56ffb::625::4f91", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 116, "passage": "As regards crypto-asset service providers, the register shall contain the following information:\n(a) the name, legal form and legal entity identifier of the crypto-asset service provider and, where applicable, of the\nbranches of the crypto-asset service provider;\n(b) the commercial name, physical address, telephone number, email and website of the crypto-asset service provider\nand, where applicable, of the trading platform for crypto-assets operated by the crypto-asset service provider;\n(c) the name and address of the competent authority that granted authorisation and its contact details;\n(d) the list of crypto-asset services provided by the crypto-asset service provider;\n(e) the list of host Member States in which the crypto-asset service provider intends to provide crypto-asset services;\n(f) the starting date, or, if not available at the time of the notification by the competent authority, the intended starting\ndate, of the provision of crypto-asset services;\n(g) any other services provided by the crypto-asset service provider not covered by this Regulation with a reference to\nthe applicable Union or national law;\n(h) the date of authorisation and, where applicable, of the withdrawal of an authorisation.\n6. Competent authorities shall notify ESMA without delay of the measures listed in Article 94(1), first subparagraph,\npoint (b), (c), (f), (l), (m), (n), (o) or (t), and of any public precautionary measures taken pursuant to Article 102 affecting\nthe provision of crypto-asset services or the issuance, offer to the public or use of crypto-assets."}], "rationale": "MiCA Title V imposes substantial personal-data processing duties on CASPs and their applicants: Article 62 application files identify management-body members with personal identifying information; Article 109 maintains a public register containing identifying details of CASPs and (where relevant) management-body members; Title V's conduct rules (Articles 68-79) require customer-suitability assessments, complaint-handling and order-execution records that involve personal data. GDPR Articles 5(1)(b)-(c) demand purpose limitation and minimisation; Article 25 requires data protection by design; Chapter V regulates cross-border transfer. The tension is operational rather than structural: GDPR Article 6(1)(c) (legal obligation) supplies the lawful basis for MiCA-mandated processing, Article 6(1)(b) covers contract performance for customer-conduct rules, and cross-border transfer to non-EEA counterparties is resolvable through Chapter V instruments. Practitioners must document the lawful-basis chain and design for purpose limitation, but no obligation in MiCA Title V is structurally incompatible with GDPR.", "compliant_paths": ["Rely on GDPR Art. 6(1)(c) (legal obligation) for MiCA Art 62/109 mandatory disclosures.", "Use Art. 6(1)(b) (contract) for customer-conduct processing under MiCA Articles 68-79.", "Apply Art. 25 data-protection-by-design when implementing MiCA's record-keeping requirements."], "out_of_scope_assumptions": ["CASP is authorised under MiCA Title V and operating in the EU; third-country firms under reverse solicitation have a different analysis (labelled separately)."]}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:ca31374863710186cee7823e", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "ESMA-Guidelines", "short_name": "ESMA Reverse Solicitation Guidelines"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3a1785f95cb37b3c::336::8d0b", "source_doc": "AMLA_Regulation_EU_2024-1620.pdf", "page": 32, "passage": "The list of\nthe selected obliged entities shall be published by the Authority without undue delay upon completion of the selection\nprocess. The Authority shall commence direct supervision of the selected obliged entities six months after publication of\nthe list.\n5. Prior to the publication of the list of the selected obliged entities, the Authority shall inform the relevant\nnon-AML/CFT authorities of the outcomes of the process of assessment and classification of inherent and residual risk of\nthe obliged entities subject to assessment.\n6. A selected obliged entity shall remain subject to direct supervision by the Authority until the Authority commences\nthe direct supervision of selected obliged entities based on a list established for the subsequent selection period which no\nlonger includes that obliged entity."}], "evidence_b": [{"chunk_id": "e3809bb1f352508e::1e2::5805", "source_doc": "Guidelines_Reverse_Solicitation_MiCA.pdf", "page": 10, "passage": "25. The reverse solicitation exemption is based on the premise that the crypto-asset product,\nservice or activity is provided at the client's own exclusive initiative. Article 61(2) of MiCA\nleaves open the possibility for the third-country firm to market to that client crypto-assets\nor crypto-asset services or activities of the same type. However, the requirement that the\ncrypto-asset services be provided on the basis of the own exclusive initiative of the client\nstill applies."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLA Regulation establishing the AML supervisor and ESMA's reverse-solicitation Guidelines under MiCA operate in disjoint regulatory domains at the obligation level. AML supervisor vs ESMA reverse-solicitation guidelines under MiCA — different subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:51:43Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:35bae0dc22d1cd2c7eba4492", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "The EU_NIS2 passage discusses the preparation of technical standards for access controls and cryptography (chunk_id 3c9eb3a25c93f394::474::4786). The SG_MAS_PRUDENTIAL_CRYPTO passage discusses the imposition of a risk-based capital framework for Stablecoin Issuers (SCS) and the principle of 'same activities, same risk, same regulation' (chunk_id 7c04f2a0bd85290a::449::02f2). The obligations are distinct: one relates to ICT security measures (access control/cryptography), while the other relates to financial prudential standards (capital requirements). There is no specific obligation in one regime that pushes against a specific obligation in the other. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:33:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:b947cd769275d31de524d36e", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_MAS_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "a82833dc0f7ca903::5f1::735d", "source_doc": "Outsourcing_Guidelines_2018.pdf", "page": 25, "passage": "5.10.2 Material outsourcing arrangements with service providers located outside Singapore\nshould be conducted in a manner so as not to hinder MAS' efforts to supervise the Singapore\nbusiness activities of the institution (i.e., from its books, accounts and documents) in a timely\nmanner, in particular:\n(a) An institution should, in principle, enter into outsourcing arrangements only\nwith service providers operating in jurisdictions that generally uphold\nconfidentiality clauses and agreements.\n\n(b) An institution should not enter into outsourcing arrangements with service\nproviders in jurisdictions where prompt access to information by MAS or\nagents appointed by MAS to act on its behalf, at the service provider, may\nbe impeded by legal or administrative restrictions. An institution must at\nleast commit to retrieve information readily from the service provider\nshould MAS request for such information. The institution should confirm in\nwriting to MAS, that the institution has provided, in its outsourcing\nagreements, for MAS to have the rights of inspecting the service provider,\nas well as the rights of access to the institution and service provider's\ninformation, reports and findings related to the outsourcing arrangement,\nas set out in paragraph 5.9.\n(c) An institution should notify MAS if any overseas authority were to seek\naccess to its customer information or if a situation were to arise where the\nrights of access of the institution and MAS set out in paragraph 5.9, have\nbeen restricted or denied."}], "rationale": "Regime A (INT_BASEL_CRYPTO) regulates capital requirements, risk-weighting of exposures, and prudential standards for banks and financial institutions. Regime B (SG_MAS_OUTSOURCING) regulates the management of outsourcing arrangements and information access for institutions operating in Singapore. The obligations in Regime A relate to financial risk and capital adequacy (e.g., defining bank exposures and risk-weighting) [32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa], while the obligations in Regime B relate to supervisory access and information retrieval regarding service providers [a82833dc0f7ca903::5f1::735d]. These are distinct regulatory domains; the capital treatment of exposures does not inherently conflict with the requirements for outsourcing information access."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:41:37Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.88, "record_type": "conflict", "pair_id": "conflict:6e357c9bd6bca5bf2ecdb27e", "label": "conflict", "regime_a": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "SG_MAS_AML_GENERAL"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "417228836d7e2aa3::379::317d", "source_doc": "MAS_Notice_PSN02_2024-04-02_rev_2025-06-30.pdf", "page": 2, "passage": "or\n(b) means an FX counterparty;\n\"relevant FX counterparty\" is a FX counterparty that is not ⎯\n(a) a financial institution as defined in section 2 of the FSM Act; or\n(b) a financial institution incorporated or established outside Singapore that is subject\nto, and supervised for compliance with, AML/CFT requirements consistent with\nstandards set by the FATF;\n\"SFA\" means the Securities and Futures Act 2001;\n\"STR\" means suspicious transaction report;\n\"STRO\" means the Suspicious Transaction Reporting Office, Commercial Affairs\nDepartment of the Singapore Police Force;\n\"transaction\" means any transaction accepted, processed, or executed by the payment\nservice provider in the course of carrying on its business of providing a digital payment\ntoken service;\n\"trust relevant party\" has the same meaning as defined in paragraph 2.1 of MAS Notice\nTCA-N03;\n[MAS Notice PSN02 (Amendment) 202"}, {"chunk_id": "d6f4be6b9d136778::4ae::d5ed", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 67, "passage": "27 These offences typically relate to cybersecurity issues such as unauthorised access. addition, MAS' off-site monitoring will also enable us to identify and target specific\nkey risks and initiate supervisory follow-up actions including for-cause inspections\nas necessary. Payment Services Act 2019\nII-3-2 ML/TF risks have been identified as the primary risk concerns posed by virtual\nassets, given the anonymity, speed and cross-border nature of transactions\nfacilitated by virtual asset providers. Under the Payment Services Act 2019 (PS\nAct), MAS will impose AML/CFT requirements on the intermediaries that buy, sell\nor exchange virtual assets in Singapore - these are the VASP business models\nidentified to be operating in Singapore. II-3-3 Under the PS Act, aligned with the FATF standards, DPT service providers are\nrequired to conduct customer due diligence and transaction monitoring measures,\nas well as to report suspicious transactions to the authorities. They are also\nrequired to screen and submit information on their customers when transferring\nDPTs to one another on behalf of their customers, and make this information\navailable on request to appropriate authorities in Singapore."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::2c4::67dd", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 2, "passage": "PART 3\nGENERAL RULES WITH RESPECT TO\nPROTECTION OFAND ACCOUNTABILITY FOR\nPERSONAL DATA\n11. Compliance with Act\n12. Policies and practices\n\n2020Ed. Act 2012 2\n\nPART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nSection\n13. Consent required\n14. Provision of consent\n15. Deemed consent\n15A. Deemed consent by notification\n16. Withdrawal of consent\n17. Collection, use and disclosure without consent\nDivision 2 - Purpose\n18. Limitation of purpose and extent\n19. Personal data collected before 2 July 2014\n20. Notification of purpose\n\nPART 5\nACCESS TO AND CORRECTION OF\nPERSONAL DATA\n21. Access to personal data\n22. Correction of personal data\n22A. Preservation of copies of personal data"}, {"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "SG_MAS_AML_GENERAL (MAS's broader AML/CFT supervisory framework — FSM Sanctions Regulations, MAS Notices SFA04-N02 and PSN02, requiring KYC/CDD and supervisory data collection on regulated entities and their customers) and SG_PDPA (Singapore PDPA — consent-based collection, use, and disclosure restrictions, Part 4). Same shape as the labelled SG_AML :: SG_PDPA conflict (careful cohort, operationally_resolvable): MAS's AML obligations require collection and ongoing use of personal data; PDPA restricts absent the 'required or authorised under any other written law' carve-out in s.13(b). Operationally resolvable via that statutory carve-out plus the MAS notices providing the legal basis.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:46Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T06:30:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.68, "record_type": "conflict", "pair_id": "conflict:b4bc2db62eff3f097d707501", "label": "conflict", "regime_a": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG FSMA DTSP licensing"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG MAS Stablecoin"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "evidence_a": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}, {"chunk_id": "cc1be49e9cf8c821::58b::dc71", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 4, "passage": "3.1 DTSPs are susceptible to higher money laundering, terrorism financing and\nproliferation financing (\"ML/TF\") risks due to the internet-based and cross-border nature of\nsuch services. This would result in a greater risk of such providers being engaged in or\nmisused for illicit purposes to the detriment of Singapore's reputation. In light of these risks,\nMAS approaches the licensing of DTSPs in a prudent and cautious manner, and there will be\nextremely limited circumstances under which MAS will consider granting an applicant a DTSP\nlicence under the FSM Act. The extremely limited circumstances include:\n• The applicant has a business model that makes economic sense, and is able to\ndemonstrate to MAS' satisfaction that it has valid reasons as to why it does not\nintend to carry on a business of providing digital token services in Singapore\ndespite operating in or being formed or incorporated in Singapore;\n• The applicant does not operate in a manner that is of concern to MAS and is\nalready regulated and supervised for its compliance with relevant internationally\nagreed standards, such as standards established by the Financial Stability\nBoard, the International Organisation of Securities Commissions and the\nFinancial Action Task Force (\"FATF\"); and\n• MAS does not have concerns with the business structure of the applicant in\nrelation to, for example, its ability to comply with regulatory obligations."}], "evidence_b": [{"chunk_id": "20d526d712753652::47d::5aaf", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "We note that one of the MAS' criteria for DTSP applicants is that they are already\nregulated and supervised for compliance with relevant internationally agreed\nstandards. For DTSP applicants that are already licensed overseas as payment\nservice providers and subject to AML/CFT requirements that are in line with FATF\nstandards, we note that under the AML Notice proposed under this regime, they will\nnot be able to rely on the CDD measures carried out by their overseas entities if such\noverseas entities are payment services providers. We note that this is consistent\nwith the approach taken under PSN02. However, we query whether this is necessary in the context of this DTSP regime,\nrecognising that there could be some differences in the AML/CFT requirements in\nthe overseas jurisdictions with those required under the FSM AML Notice and\nparticularly since DTSPs would not have Singapore customers or business in\nSingapore. Many DTSP applicants are likely to rely on existing compliance officers of\ntheir overseas regulated entities who are already responsible to ensure AML/CFT\nand CDD compliance with the requirements of their home regulator."}, {"chunk_id": "7c04f2a0bd85290a::429::7290", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "Specifically, we would like to seek clarity on the application of provisions in the PS Act\nrelating to licensing of payment service providers, and the prohibition against solicitation. 15 August 2023 | 92\n(a) Will section 5 of the PS Act prohibit Overseas Issuers from carrying on a business of\nproviding regulated SCS issuance services in Singapore? Or will Overseas Issuers be\nprohibited from carrying on a business of providing any stablecoin issuance services in\nSingapore? (b) Will section 9 of the PS Act prohibit Overseas Issuers from offering to provide\nregulated SCS issuance services in Singapore? Or will Overseas Issuers be prohibited from\noffering to provide any stablecoin issuance services in Singapore? Question 2. MAS seeks comments on whether it is sufficient to introduce an additional regulated\npayment service of stablecoin issuance, and whether there is a need to introduce any\nother regulated services specific to stablecoins. We are supportive of the intention to introduce an additional regulated payment service\nof SCS/stablecoin issuance."}], "rationale": "FSM Act Part 9 (operationalised by section 137) requires any person 'conducting digital token services in Singapore' to hold a DTSP licence unless exempt; Section 137(5) sets out the applicable exemptions. The DTSP Guidelines flag the cross-border / internet-based nature of DTSP services and their ML/TF exposure. Whether a foreign stablecoin issuer is 'conducting digital token services in Singapore' — and therefore subject to the DTSP licensing regime — depends on fact-sensitive elements: physical presence, marketing reach to SG residents, governing-law election, and contractual touchpoints. Industry submissions directly ask MAS to clarify whether PS Act s 5's prohibition on soliciting captures overseas issuers and how it interacts with FSMA DTSP licensing. This is fact-sensitive in the same vein as the SG_PSA_DPT :: SG_STABLECOIN pair.", "compliant_paths": ["Document geographic split of customer base; structure operations so that no part of the digital-token-service value chain is conducted in Singapore unless under a DTSP licence."], "out_of_scope_assumptions": ["Foreign stablecoin issuer with no physical presence in SG; question is purely about extraterritorial DTSP licence reach."]}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:c134e45ee3e55213124eb059", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "FATF", "short_name": "FATF R.16 Travel Rule"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "FATF", "short_name": "FATF Updated VA/VASP Guidance"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85240528438654b9::207::feef", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline (1).pdf", "page": 58, "passage": "178. As set out in INR. 15, countries should apply Recommendation 16 to VA transfers\nand VASPs. Countries should apply Recommendation 16 regardless of whether the\nvalue of the traditional wire transfer or the VA transfer is denominated in fiat\ncurrency or a VA. However, recognising the unique technological properties of VAs,\nRecommendation 16 applies in an amended way to VAs as set out in paragraph 7(b)\nof INR.15. The application of the FATF's wire transfer requirements in the VA\ncontext is called the travel rule."}], "evidence_b": [{"chunk_id": "85240528438654b9::2a1::63ef", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline (1).pdf", "page": 53, "passage": "40 See 2015 VC Guidance, paragraph 44 as well as June 2013 Guidance for a Risk-Based\nApproach to New Payment Products and Services, paragraph 66.\n\n52  UPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS\nor services, and conducting ongoing due diligence (see Section IV for further\ndiscussion on ongoing due diligence and monitoring obligations for VASPs and\nother obliged entities). Such transactional and record reviews are vital for effective\nsupervision and are an important data source for the transfer of the required\nrelevant customer information for compliance with the 'travel rule' (see\nRecommendation 16).\nRecord-keeping"}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): FATF Recommendation 16 travel rule and FATF VA/VASP Updated Guidance are designed to coexist — obligations apply cumulatively without collision. Same FATF authority — Recommendation 16 plus the detailed VA/VASP guidance that operationalises it for virtual assets. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:18:47Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:d74d32a1b0a413c48cce09cc", "label": "non_conflict", "regime_a": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "The IOSCO General Principles passage (chunk_id f173909614befd49::455::1a1a) outlines high-level objectives and standards for securities regulation, focusing on cooperation and market integrity. The Singapore PDPA passage (chunk_id 0e996ae99839f19e::37b::85a8) regulates the collection, use, and disclosure of personal data, requiring consent. The obligations in these regimes regulate distinct domains—financial market regulation versus data protection—resulting in no direct conflict between the specific obligations cited."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:15010ba59c0005ba1addbcb8", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiFID II"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "PSD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "28dfda0f6a6539b6::49c::69f4", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 53, "passage": "Member States shall require that investment firms and market operators operating an MTF or an OTF establish,\npublish and maintain and implement transparent and non-discriminatory rules, based on objective criteria, governing\naccess to its facility.\n4. Member States shall require that investment firms and market operators operating an MTF or an OTF have\narrangements to identify clearly and manage the potential adverse consequences for the operation of the MTF or OTF,\nor for the members or participants and users, of any conflict of interest between the interest of the MTF, the OTF, their\nowners or the investment firm or market operator operating the MTF or OTF and the sound functioning of the MTF or\nOTF.\n5. Member States shall require that investment firms and market operators operating an MTF or OTF comply with\nArticles 48 and 49 and have in place all the necessary effective systems, procedures and arrangements to do so.\n6. Member States shall require that investment firms and market operators operating an MTF or an OTF clearly inform\nits members or participants of their respective responsibilities for the settlement of the transactions executed in that\nfacility."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::43b::29d2", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 6, "passage": "(30) The personalised security credentials used for secure customer authentication by the payment service user or by the\npayment initiation service provider are usually those issued by the account servicing payment service providers.\nPayment initiation service providers do not necessarily enter into a contractual relationship with the account\nservicing payment service providers and, regardless of the business model used by the payment initiation service\nproviders, the account servicing payment service providers should make it possible for payment initiation service\nproviders to rely on the authentication procedures provided by the account servicing payments service providers to\ninitiate a specific payment on behalf of the payer.\n\n(31) When exclusively providing payment initiation services, the payment initiation service provider does not at any\nstage of the payment chain hold the user's funds. When a payment initiation service provider intends to provide\npayment services in relation to which it holds user funds, it should obtain full authorisation for those services."}], "rationale": "MiFID II governs investment-firm conduct (suitability, appropriateness, best execution, trading venue rules); PSD2 governs payment-service-provider conduct (strong customer authentication, open banking, payment instruments). They apply to substantively non-overlapping populations — an investment firm is not by default a PSP and vice versa. Hard negative.", "would_conflict_if": ["MiFID II suitability rules required disclosure of payment-account-access permissions that PSD2 strong customer authentication confidentiality rules forbade — no such conflict in current text."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:19:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:70a18cd62138044d15842528", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The passages from INT_BASEL_CRYPTO describe prudential capital requirements for banks and financial institutions, specifically defining 'bank exposures' and risk-weighting methodologies (chunk_ids 32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). The passages from SG_FOUNDATIONAL_LEGISLATION describe MAS enforcement actions against ICO issuers and exchanges, and the intention to expand legislation to cover virtual asset service providers (chunk_ids b49627bb889ef1d9::3ef::7168, d6f4be6b9d136778::467::12af). These two regimes regulate distinct aspects of the financial system: Basel regulates capital adequacy and risk management for banks, while MAS regulates the conduct and licensing of digital token issuers and exchanges. There is no specific obligation in the Basel framework that conflicts with the MAS directives on digital tokens."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:11:55Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:25de104ae3f709f9c5cda79f", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "08b3db1cc7362f25::3bb::5dba", "source_doc": "Guidance-Correspondent-Banking-Services.pdf.coredownload.pdf", "page": null, "passage": "FATF GUIDANCE\nCORRESPONDENT\nBANKING SERVICES\nOCTOBER 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on correspondent banking services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/correspondent-banking-services.html\n© 2016 FATF/OECD."}], "rationale": "The obligations in Prudential Standard CPS 230 (Regime A) relate to operational risk management, business continuity, and the resilience of critical operations for APRA-regulated entities. The obligations in the FATF General Guidance (Regime B) relate to anti-money laundering (AML), counter-terrorist financing (CFT), and the assessment of cross-border risks. The passages confirm that these regimes regulate distinct domains: one focuses on the resilience of critical operations and service provider management, while the other focuses on the detection of criminal proceeds and suspicious transactions. There is no specific obligation in CPS 230 that pushes against a specific obligation in FATF General Guidance, nor do the regimes apply to the same subject matter in a conflicting manner."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:be7c449b4ed2f1a8c9870ea7", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}, {"chunk_id": "c51ad46265cea4e5::361::e378", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 16, "passage": "57. ESMA is mandated in Article 84(4) of MiCA to develop, in close cooperation with EBA,\ndraft regulatory technical standards (RTS) on the detailed content of the information for\nthe assessment of proposed acquisitions of qualifying holdings in CASPs. The aim of\nthis draft RTS is to specify the detailed content of the information that direct or indirect\nproposed acquirers must provide to national competent authorities (NCAs) when\nnotifying the intended acquisition. This should ensure a harmonised approach to the\nassessment across Member States in the EU of the intended acquisition of qualifying\nholdings in CASPs.\n\n58. The RTSs are applicable to proposed acquirers of qualifying holdings in CASPs, as well\nas NCAs as designated under Article 93(1) of MiCA that will conduct the assessment of\nthe intended acquisition in accordance with Article 83(4) of MiCA."}], "rationale": "AU_ASIC_CRYPTO (ASIC's INFO 225 / financial-product classification of digital assets and AFSL licensing) and EU_MICA_RTS (EU technical standards for CASP authorisation and qualifying-holding acquisitions under MiCA). Both regulate crypto-asset service providers but in different jurisdictions with materially different mechanisms (AU financial-product status under the Corporations Act vs EU CASP authorisation framework). Distinct perimeters; no obligation conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.82, "record_type": "conflict", "pair_id": "conflict:868f8219e37205100ebd482b", "label": "conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "conflict_type": "recurring_friction", "severity": "medium", "evidence_a": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}, {"chunk_id": "c0300673081f7232::498::163c", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(9) At international level, the Organisation for Economic Cooperation and Development (OECD) Crypto-Asset\nReporting Framework, set out in Part I of the document 'Crypto-Asset Reporting Framework and Amendments to\nthe Common Reporting Standard' approved by the OECD on 26 August 2022(the 'OECD Crypto-Asset Reporting\nFramework'), is aimed at introducing greater tax transparency with regard to crypto-assets and their reporting.\nUnion rules should take into account the framework developed by the OECD in order to increase the effectiveness\nof the exchange of information and to reduce administrative burden. In implementing this Directive, Member States\nshould use the Commentaries on the Model Competent Authority Agreement, set out in the document 'International\nStandards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023\nupdate to the Common Reporting Standard', released by the OECD on 8 June 2023 (the 'Commentaries on the\nModel Competent Authority Agreement'), and the OECD Crypto-Asset Reporting Framework as sources of\nillustration or interpretation and in order to ensure consistency in application across Member States."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::2bc::cafa", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 9, "passage": "19. Article 62(4) of MiCA sets out that NCAs must not require an applicant CASP to provide\nany information referred to in Article 62(2) of MiCA that they have already received under\nthe respective authorisation procedures in accordance with Directive 2009/110/EC4,\n2014/65/EU5 or (EU) 2015/23666, or pursuant to national law applicable to crypto-asset\nservices prior to the date of entry into force of MiCA, provided that such previously\nsubmitted information or documents are still up-to-date.\n\n3.2 Feedback statement\nQ2: Do you agree with the list of information to be provided with an application for\nauthorisation as a crypto-asset service provider? Please also state the reasons for your\nanswer."}], "rationale": "EU_DAC8 (EU directive on administrative cooperation for crypto-asset reporting — CASPs must report user data to tax authorities) and EU_MICA_TITLE_V_CASP (EU CASP authorisation framework). The friction is recurring: every crypto-asset transaction or relationship MiCA's CASPs handle generates DAC8 reporting obligations. The two regimes are aligned in policy direction but the combined operational cost on CASPs scales with transaction count — a built-in friction of the regulatory design.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:33Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:21:46Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:29f18997507b8af12b2b3996", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}, {"chunk_id": "33d059aa86716ddd::4ed::8511", "source_doc": "2022_CP_Stablecoin_Regulatory_Approach.pdf", "page": 6, "passage": "3.5 A wide range of stablecoins currently exist, varying in terms of their asset-\npegging, as well as the mechanism that upholds the stability of the stablecoins' value\nagainst the pegged asset(s). MAS intends to focus its regulatory regime on:\nSingle-currency pegged stablecoins (SCS) - As compared to other types of\nstablecoins (such as those pegged to a basket of currencies or other\nassets such as commodities), SCS has a stronger use case for payment and\nsettlement.\nNon-SCS will continue to be subject to the existing DPT regime under the\nPS Act. MAS views such stablecoins as being less stable in nominal value\nand should be treated differently from SCS.\nIn addition, even among SCS, there is variation in the stabilisation\nmechanism. MAS views stablecoins which are algorithmically-pegged,\nunbacked or backed by other cryptocurrencies to be more susceptible to\nvolatility in value. Correspondingly, such stablecoins will also continue to\nbe treated as DPTs.\nSCS issued in Singapore - The immediate priority of MAS is to elevate the\nstandard of SCS issued in Singapore. Our regulatory perimeter is thus\nscoped based on MAS' ability to directly impose requirements on the\nreserve management, redemption policies and prudential standards of\nthe SCS issuer."}], "rationale": "The EU_MAR regime regulates market abuse, insider dealing, and market manipulation in financial instruments (chunk_ids 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The SG_STABLECOIN regime regulates the issuance and reserve management of Single Currency Stablecoins (SCS) issued in Singapore (chunk_ids 58f45cd2ef3de201::36c::e2f6, 33d059aa86716ddd::4ed::8511). The obligations in EU_MAR relate to the conduct of trading and the prevention of market abuse, whereas the obligations in SG_STABLECOIN relate to the issuance standards and reserve requirements for specific digital assets. The two regimes regulate distinct domains of activity and do not impose conflicting obligations on the same conduct."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:42:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f14d09a89720625d00958c3a", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::46d::fd1b", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "Binance is supportive of the redemption-related requirements. In general, five business\ndays should be sufficient to return the par value of the SCS to customers. However, given\nthat this is ultimately dependent on the availability of the relevant banking services,\nBinance would propose that this is aligned to the prevailing turnaround time provided by\nthe financial institution that the reserve assets are held with. Question 7. MAS seeks comments on whether the prudential requirements outlined in paragraph\n4.21 are risk proportionate. MAS welcomes suggestions on alternative approaches to\naddress the risks. Binance is supportive of the prudential requirements outlined in paragraph 4.21. 15 August 2023 | 23\nQuestion 10. MAS seeks comments on whether the scenario outlined in paragraph 4.22 is a likely\ndevelopment and whether the approaches outlined in paragraph 4.24 are feasible. MAS\nwelcomes suggestions on other approaches to address this issue. As per Q1, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction."}], "rationale": "The EU MICA Title IV EMT passages regulate the content and liability of crypto-asset white papers for issuers of e-money tokens (e.g., Article 51 notification requirements and Article 52 liability for misleading information). The SG MAS Prudential Crypto passages discuss the submission of consultation papers, the submission of written comments, and the general prudential treatment of cryptoasset exposures (e.g., paragraph 4.21). There is no specific obligation in the SG MAS passages that creates a conflict with the specific obligations in the EU MICA passages regarding white paper content, notification, or liability. The SG passages focus on the regulatory process and prudential standards, whereas the EU passages focus on the specific disclosure requirements for issuers. Therefore, the regimes do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:09:33Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:6ce1807830880e4c93bac8a1", "label": "conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::34a::74e3", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 11, "passage": "33. Article 109(1)(d) MiCA requires ESMA to establish a register of CASPs which must be\npublicly available on its website and be updated on a regular basis. Article 109(5) MiCA\nspecifies the information which the register must contain, including the name, legal form\nand legal entity identifier of the CASP and, where applicable, of the where applicable, of\nthe CASP's branches and the list of crypto-asset services provided by the CASP. To\nensure that an application for authorisation also contains all information required for the\nfuture ESMA public register of CASPs, ESMA proposes to include a few additional\ninformation requirements of limited extent to reflect the requirements of Article 109(5) of\nMiCA in the draft RTS on the application for authorisation as a CASP.\n\n4 Complaints-handling procedures of crypto-asset service\nproviders"}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}, {"chunk_id": "0e996ae99839f19e::61d::14e5", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "23 Act 2012 2020Ed. Deemed consent by notification\n15A.-(1) This section applies to the collection, use or disclosure\nof personal data about an individual by an organisation on or after\n1 February 2021.\n[40/2020]\n(2) Subject to subsection (3), an individual is deemed to consent to\nthe collection, use or disclosure of personal data about the individual\nby an organisation if -\n(a) the organisation satisfies the requirements in\nsubsection (4); and\n(b) the individual does not notify the organisation, before the\nexpiry of the period mentioned in subsection (4)(b)(iii),\nthat the individual does not consent to the proposed\ncollection, use or disclosure of the personal data by the\norganisation.\n[40/2020]\n(3) Subsection(2)doesnotapplytothecollection,useordisclosure\nof personal data about the individual for any prescribed purpose.\n[40/2020]\n(4) For the purposes of subsection (2)(a), the organisation must,\nbefore collecting, using or disclosing any personal data about the\nindividual -\n(a) conduct an assessment to determine that the proposed\ncollection, use or disclosure of the personal data is not\nlikely to have an adverse effect on the individual;\n(b) take reasonable steps to bring the following information to\nthe attention of the individual:\n(i) theorganisation'sintentiontocollect,useordisclose\nthe personal data;\n(ii) the purpose for which the personal data will be\ncollected, used or disclosed;\n(iii) a reasonable period within which, and a reasonable\nmanner by which, the individual may notify the\norganisation that the individual does not consent to"}], "rationale": "EU_MICA_TITLE_V_CASP (EU MiCA Article 62+ — CASP authorisation framework requiring customer due diligence, AML data collection, and information accompanying crypto-asset transfers under the linked TFR) and SG_PDPA (Singapore PDPA Part 4 — consent-based collection, use, and disclosure restrictions). When EU CASPs serve SG-resident clients or transmit data to SG-licensed counterparty CASPs, the MiCA/TFR-mandated personal-data transmission engages PDPA's consent/disclosure restrictions on the SG side. Operationally resolvable via PDPA s.13(b) ('required or authorised under any other written law') carve-out plus the SG MAS AML/CFT framework as the SG-side legal authorisation. Same shape as the labelled EU TFR ↔ EU GDPR conflict in the careful cohort, scaled to the EU↔SG cross-jurisdictional framing.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:09Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:35:03Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:1422269129bfd5101de57ec0", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "The AU_TTR_THRESHOLD regime regulates the reporting of physical cash transfers exceeding A$10,000 to AUSTRAC under the AML/CTF Act. The SG_FSMA_DTSP regime regulates the licensing and conduct of Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022. The evidence shows that the SG regime applies to individuals, partnerships, or corporations conducting digital token services (chunk_id cc1be49e9cf8c821::2f4::ea8f), whereas the AU regime applies to reporting entities providing designated services involving physical currency transfers (chunk_id 6dfe4e63b9fb3c74::3bc::1a3f). The obligations are distinct: one concerns the reporting of physical cash thresholds, and the other concerns the licensing of digital token service providers. There is no specific obligation in the SG regime that conflicts with the AU reporting obligation, nor do the regimes regulate the same subject matter. Therefore, the regimes are in non_conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:d936a4fe96a6c6fd2c6a89b5", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 230"}, "regime_b": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU Travel Rule (IFTI)"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "561fc09c315f8349::45d::68bb", "source_doc": "Money transferred to and from overseas International funds transfer instruction (IFTI) reports.pdf", "page": null, "passage": "In\nan IFTI-E: e the transfer instruction is carried out or passed on electronically https://www.austrac.gov.au/business/core-guidance/reporting/money-transferred-and-overseas-international-funds-transfer-instruction-ifti-reports 2/6 25/06/2025, 23:15 Money transferred to and from overseas: International funds transfer instruction (IFTI) reports | AUSTRAC e the transfer is within the same financial institution or between financial\ninstitutions, such as banks, building societies or credit unions. An IFTI-E can be either:\ne outgoing - the ordering institution accepts the instruction in Australia and transfers money to the payee via a beneficiary institution overseas e incoming - the ordering institution accepts the instruction overseas and\ntransfers money via a beneficiary institution in Australia. Information required in IFTI-E reports\nIFTI-E reports must include details about everyone involved in the transfer:\ne the payer - the business, organisation or individual who instructs the ordering\ninstitution to transfer money\ne the ordering institution - the institution that accepts the transfer instruction"}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): APRA CPS 230 operational-risk management standard and AUSTRAC IFTI / EFTI travel-rule reporting operate in disjoint regulatory domains at the obligation level. Operational risk vs AML wire-transfer information rules — disjoint subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:43:40Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:7ebe2a444fc0449088abd457", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::25d::6825", "source_doc": "d424.pdf", "page": 85, "passage": "150. At national supervisory discretion, banks using both the standardised and IRB approaches may\nrely on their internal methods for allocating general provisions for recognition in capital under either the\nstandardised or IRB approach, subject to the following conditions. Where the internal allocation method\nBasel III: Finalising post-crisis reforms 81\n\nis made available, the national supervisor will establish the standards surrounding their use. Banks will\nneed to obtain prior approval from their supervisors to use an internal allocation method for this purpose.\n\n3. Treatment of EL and provisions"}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The Basel III framework (Regime A) regulates banking capital adequacy, leverage ratios, and risk-weighted assets (RWA) for banks, including the treatment of fiduciary assets and general provisions (chunk_ids 32afd37cade34f84::34b::8d30, 32afd37cade34f84::25d::6825). In contrast, the Singapore foundational legislation (Regime B) focuses on the regulation of digital tokens, securities token offerings, and the Payment Services Act (chunk_ids b49627bb889ef1d9::3ef::7168, d6f4be6b9d136778::467::12af). The obligations in Regime A relate to financial accounting and capital management for banks, while Regime B addresses consumer protection and AML/CFT compliance for digital asset service providers. There is no specific obligation in the Basel framework that conflicts with the obligations in the Singapore foundational legislation regarding digital tokens or payment services. Therefore, the regimes regulate different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:58:33Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:2562694be6c0d1bc4a9bf3d1", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}], "rationale": "The regimes regulate distinct aspects of the digital asset ecosystem. Regime A (AU_TREASURY_DAP) focuses on the 'token mapping' exercise and the development of a licensing and custody framework for crypto asset service providers to fit assets within the financial services framework. Regime B (SG_IRAS_TAX) focuses on the Goods and Services Tax (GST) treatment of digital payment tokens, specifically that their supply is exempt from GST and that businesses trading in them are no longer liable for GST registration. The obligations in Regime A regarding licensing and perimeter demarcation do not conflict with the GST treatment obligations in Regime B; they address different regulatory domains (financial services regulation vs. tax treatment)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:24:00Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:1d4ba266b06fb985bc359cba", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::353::debc", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 14, "passage": "(69)\nThe crypto-asset white paper drawn up by an issuer of e-money tokens should contain all information concerning\nthat issuer and the offer of e-money tokens or their admission to trading that is necessary to enable prospective\nbuyers to make an informed purchase decision and understand the risks relating to the offer of e-money tokens.\nThe crypto-asset white paper should also expressly refer to the right of holders of e-money tokens to redeem their\ne-money tokens for funds denominated in the official currency that the e-money tokens reference at par value\nand at any time.\n\n(70)\nWhere an issuer of e-money tokens invests the funds received in exchange for e-money tokens, such funds should\nbe invested in assets denominated in the same official currency as the one that the e-money token is referencing\nin order to avoid cross-currency risks."}], "rationale": "The evidence for APRA CPS234 (chunk 4b6fab404e7acfca::3c4::1564) establishes that the guide is a non-binding 'Prudential Practice Guide' offering guidance on Operational Risk Management for APRA-regulated entities. The evidence for EU MICA Title IV EMT (chunk 491a2f0014d56ffb::353::debc) outlines the content requirements for a 'crypto-asset white paper' for issuers of e-money tokens. The obligations in the EU regime relate to the disclosure of information in a white paper to prospective buyers, whereas the APRA regime addresses operational risk management frameworks. These are distinct regulatory domains; the EU obligations do not impose a specific operational risk management framework on the issuer that conflicts with the APRA guidance."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:46:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:ca3fed19d0442b9457522032", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU AML/CTF (AUSTRAC guidance)"}, "regime_b": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU AML/CTF Act + Rules"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}, {"chunk_id": "d38ec0ddcc912963::450::6872", "source_doc": "Reporting.pdf", "page": null, "passage": "'@ Australian Government Cee ee\nahem 8 eporting Home / Business / Core guidance / Reporting As a reporting entity you must report certain transactions and suspicious matters, and\nsubmit compliance reports to AUSTRAC. Everyone, including reporting entities, must\nreport cross-border movements of physical currency. Ongoing reporting obligations Threshold transaction reports You must submit threshold transaction reports (TTR) for transfers of A$10,000 or more\nin cash (or the foreign currency equivalent). TTRs are due within 10 business days after\nthe date of the transaction. International funds transfer instruction reports (IFTIs) You must submit international funds transfer instruction reports (IFTIs) for transfers of\nfunds of any value into or out of Australia, made either electronically or under a\ndesignated remittance arrangement. IFTIs are due within 10 business days after the\ntransfer instruction is sent or received. Suspicious matter reports (SMRs) You must submit suspicious matter reports (SMRs) when you have a suspicion that a\ncustomer or transaction is related to criminal activity."}], "evidence_b": [{"chunk_id": "254ca2d92d196180::369::b111", "source_doc": "Anti-Money Laundering act 2006.pdf", "page": 98, "passage": "Part 2 Identification procedures etc. Division 2 Identification procedures for certain pre-commencement customers\nSection 29\n(b) after the commencement of this section, a suspicious matter\nreporting obligation arises for the reporting entity in relation\nto the customer. Note 1: For suspicious matter reporting obligation, see section 41. Note 2: For tipping-off offences, see section 123. Requirement\n(2) The reporting entity must:\n(a) take such action as is specified in the AML/CTF Rules; and\n(b) do so within the time limit allowed under the AML/CTF\nRules. Civil penalty\n(3) Subsection (2) is a civil penalty provision. Interpretation\n(4) For the purposes of this section, assume that Part 1 had been in\nforce at all material times before the commencement of this\nsection.\n80 Anti-Money Laundering and Counter-Terrorism Financing Act 2006 Identification procedures etc."}, {"chunk_id": "50f54f147dcb1cba::30a::639e", "source_doc": "AML_CTF_Rules_2007.pdf", "page": 103, "passage": "Note: Where a reporting entity is unable to ascertain whether the circumstances in\n19.3(17)(a) applies, the reporting entity can assume that the transaction was\ncarried out by the customer.\n19.4 If the threshold transaction arises under a designated service that is of a kind\ndescribed in item 3 of table 1 in subsection 6(2) of the AML/CTF Act, the\nreference to 'customer' in subparagraphs 19.3(2) to 19.3(14) inclusive will\nbe taken, in the first instance, to refer only to the holder of the account and\nthe signatory (if any) conducting the transaction in relation to the account,\nprovided that:\n(1) if there are other signatories to the account, the AUSTRAC CEO may\nrequire the reporting entity to give to the AUSTRAC CEO, in the\nform of a supplement to the subsection 43(2)"}], "rationale": "AU_AML_CTF (AUSTRAC-issuing-body view) and AU_FEDREG_AML (FederalRegister-issuing-body view) are two registry-level facets of the *same* Australian AML/CTF regime — the AML/CTF Act 2006, AML/CTF Rules and AUSTRAC operational guidance. They are split in the regime registry because the chunked corpus stores them under different issuing-body directories (AUSTRAC operational guidance vs FederalRegister statutory instruments), not because they are different regimes. No conflict is possible — they are literally the same regime. Trivial hard negative; included to give the trainer an intra-regime alignment example.", "would_conflict_if": ["AUSTRAC guidance contradicted the binding Act/Rules — pure operational risk, not a regime-level conflict."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:ca3fed19d0442b9457522032", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}, {"chunk_id": "50f54f147dcb1cba::595::23af", "source_doc": "AML_CTF_Rules_2007.pdf", "page": 229, "passage": "For further information about\nthese obligations, please go to http://www.oaic.gov.au or call 1300 363 992. Anti-Money Laundering and Counter-Terrorism Financing 221\nRules Instrument 2007 (No. 1) Reporting obligations of registered remittance affiliates CHAPTER 54\nCHAPTER 54 Reporting obligations of registered\nremittance affiliates\n54.1 These Anti-Money Laundering and Counter-Terrorism Financing Rules\n(Rules) are made under section 229 of the Anti-Money Laundering and\nCounter-Terrorism Financing Act 2006 (AML/CTF Act) for the purpose of\nsubsections 49A(1) and 49A(2) of that Act and in reliance on section 4 of the\nActs Interpretation Act 1901. These Rules come into effect on the date that\nsection 49A comes into effect.\n54.2 An obligation imposed by subsection 43(2) or 45(2) of the AML/CTF Act\nupon a registered remittance affiliate of a registered remittance network\nprovider to give a report to the AUSTRAC CEO is taken instead to be an\nobligation imposed upon, and must be discharged by, the registered\nremittance network provider.\n54.3 If a suspicious matter reporting obligation imposed by subsection 41(1) of\nthe AML/CTF Act upon a registered remittance affiliate of a registered\nremittance network provider arises, that obligation may be met by the\nregistered remittance network provider under a written agreement in place\nbetween the registered remittance affiliate and the registered remittance\nnetwork provider."}], "evidence_b": [{"chunk_id": "86b8c938e66f203a::3e8::06bf", "source_doc": "AML rules 2007.pdf", "page": 93, "passage": "Part 8.9 Reporting obligations\n8.9.1 Part A of a reporting entity's AML/CTF program must include:\n(1) the obligations that apply to the reporting entity under sections 41, 43,\n45 and 47 of the AML/CTF Act (reporting obligations); and\n(2) appropriate systems and controls of the reporting entity designed to\nensure compliance with the reporting obligations of the reporting\nentity; and\n(3) the obligations that apply to the reporting entity under section 51F of\nthe AML/CTF Act and Chapter 64 of the AML/CTF Rules; and\n(4) where the reporting entity is a remittance dealer, the obligations that\napply to the remittance dealer under section 75M of the AML/CTF Act\n(as applicable) to advise:\n(a) the AUSTRAC CEO of material changes in circumstances and\nother specified circumstances under subsections 75M(1) and\n75M(3) of the AML/CTF Act; or\n(b) the registered remittance network provider of material changes in\ncircumstances and other specified circumstances under\nsubsection 75M(2) of the AML/CTF Act."}, {"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "rationale": "AU_AML_CTF (Australia's AML/CTF Act 2006 — primary statute) and AU_FEDREG_AML (Federal Register hosting of the AML/CTF Rules 2007 and related instruments). These are the same domestic AU AML/CTF framework accessed through different layers (Act vs Rules); they operate together and reinforce each other within Australia's coordinated AML architecture. Aligned by design."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:25:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:7c03a9ba0fcfe2590f54eb36", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}], "rationale": "The evidence from the Australian Tax Office (AU_ATO_CRYPTO) passage focuses on the tax treatment and adoption of crypto assets in Australia (chunk_id e6bb47e92e88e16c::567::36c4). The evidence from the Monetary Authority of Singapore (SG_MAS_AML_GENERAL) passage discusses the transitional exemption for Digital Payment Token (DPT) service providers operating under the Payment Services Act (chunk_id 321e082bdbe732d3::309::b080). The obligations described in the Australian passage relate to taxation and reporting, while the obligations in the Singaporean passage relate to licensing and regulatory exemptions for payment services. These are distinct regulatory domains with no apparent overlap of obligations that would create a conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:09:05Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:480f8bd5506194aef0291f53", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "9a96d4d1812f257a::2a6::2422", "source_doc": "161011-APRA-RIS-margining-risk-mitigation-final-assessment-second-pass.pdf", "page": 2, "passage": "2 APRA's prudential framework comprises prudential standards and prudential practice guides (PPGs). APRA is\nempowered to issue legally binding prudential standards that set out specific requirements with which APRA-regulated\ninstitutions - authorised deposit-taking institutions (ADIs), general insurers and life companies (collectively,\ninsurers) and registrable superannuation entity licensees (RSE licensees) - must comply. APRA also issues PPGs,\nwhich clarify APRA's expectations with regard to prudential matters. PPGs frequently discuss legal requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}], "rationale": "The evidence for APRA focuses on prudential standards, capital requirements, and supervisory frameworks for financial institutions (chunk 9a96d4d1812f257a::2a6::2422). The evidence for MAR focuses on market abuse, insider dealing, and market manipulation (chunk 5cc4a27bc578287a::165::3333). The obligations described in the APRA passage relate to the solvency and stability of regulated institutions, while the obligations in the MAR passage relate to the integrity of financial markets and investor protection. These are distinct regulatory domains with no apparent overlap of specific obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:10:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:521fde310e2268a7439d533d", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "cf4bab4773787409::1e6::5413", "source_doc": "FinalReport_Recovery_Plans_MiCAR.pdf", "page": 6, "passage": "2 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational\nresilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU)\nNo 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1).\n\n3. Guidelines\n\nEBA/GL/2024/07\n13June 2024\nGuidelines\non recovery plans under Articles 46 and 55 of the Regulation (EU)\n\n1. Compliance and reporting\nobligations\nStatus of these guidelines"}], "rationale": "The evidence for Regime A (AU_APRA_CPS230) focuses on operational risk management, business continuity, and service provider management within the Australian financial sector. The evidence for Regime B (EU_EMD2) refers to the 'Digital Operational Resilience for the financial sector' and amending regulations, but the provided chunks do not contain specific operational obligations or requirements. Without specific obligations in Regime B that contradict or impose conflicting requirements on the topics covered in Regime A (such as BCPs or service provider management), the regimes do not conflict. The evidence suggests they address similar domains (operational resilience) but the specific obligations are not grounded in the provided text for Regime B."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:18:51Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:e34bc9d1ff639f95596619a0", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "The EU MIFID2 passages regulate the conduct of investment firms regarding product governance, suitability assessments, and client communication (e.g., Article 24 and 25). The SG_AML passages regulate AML/CFT compliance, specifically requiring training for officers and employees on AML/CFT laws and CDD measures (Clause 13.14). The obligations in MIFID2 relate to the suitability of financial instruments and the fair presentation of information to clients, whereas the obligations in SG_AML relate to the prevention of money laundering and terrorism financing. These are distinct regulatory domains; the SG AML requirements do not impose specific obligations on the suitability of financial instruments or the disclosure of investment advice independence that would conflict with MIFID2. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:c0ae404310d6b62b12a446ef", "label": "conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "AU_TTR_THRESHOLD (AUSTRAC threshold-transaction reports of AUD 10,000+ — mandatory AML data disclosure by AU reporting entities) and SG_PDPA (Singapore Personal Data Protection Act restricting collection/disclosure of personal data without consent or statutory authorisation). When an AU reporting entity has SG-resident customers and submits TTR data to AUSTRAC, the cross-border movement of that personal data engages PDPA restrictions on the SG side. Operationally resolvable via PDPA s.13(b) ('required or authorised under any other written law') for AML compliance. Severity low because the overlap is narrow (most TTRs concern AU residents) and the resolution path is established.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:36Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:10:54Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:66a13c22e33db2068a9b48dd", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}], "rationale": "The EU MiCA RTS passages focus on the notification requirements for financial entities providing crypto-asset services and the detailed content of information for assessing acquisitions of qualifying holdings in CASPs (c51ad46265cea4e5::2f5::4513, c51ad46265cea4e5::361::e378). The FATF R16 passages focus on global anti-money laundering (AML) and counter-terrorist financing (CFT) standards, specifically guidance on digital identity and red flag indicators for virtual assets (5d489619a0fb9ecf::377::a91e, d758cb6128239f36::429::2caa). The obligations in MiCA regarding market conduct and licensing do not directly contradict the FATF's AML/CFT risk-based approach obligations; rather, they operate in complementary domains where MiCA establishes the regulatory perimeter for crypto-asset service providers and FATF provides the global AML/CFT framework for them."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:59:02Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:23980b26e76d92dd1bb07ab1", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "9a96d4d1812f257a::2a6::2422", "source_doc": "161011-APRA-RIS-margining-risk-mitigation-final-assessment-second-pass.pdf", "page": 2, "passage": "2 APRA's prudential framework comprises prudential standards and prudential practice guides (PPGs). APRA is\nempowered to issue legally binding prudential standards that set out specific requirements with which APRA-regulated\ninstitutions - authorised deposit-taking institutions (ADIs), general insurers and life companies (collectively,\ninsurers) and registrable superannuation entity licensees (RSE licensees) - must comply. APRA also issues PPGs,\nwhich clarify APRA's expectations with regard to prudential matters. PPGs frequently discuss legal requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}], "rationale": "The evidence from APRA (chunk 9a96d4d1812f257a::2a6::2422) describes a prudential framework for traditional financial institutions (ADIs, insurers, RSE licensees) that focuses on capital requirements, licensing, and supervision. The evidence from MiCA (chunk c51ad46265cea4e5::147::6214) establishes a legal framework for crypto-asset service providers (CASPs) requiring authorisation. The obligations and regulated entities are distinct; APRA regulates traditional financial institutions, while MiCA regulates crypto-asset service providers. There is no evidence of a specific obligation in APRA's regime conflicting with MiCA's obligations regarding crypto-asset services."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:57:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:477e0c6034e15400b383871c", "label": "non_conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "adb1a81b9cecaf8c::3ac::b555", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 16, "passage": "(89) Provision of payment services by the payment services providers may entail processing of personal data. Directive\n95/46/EC of the European Parliament and of the Council ( 1) , the national rules which transpose Directive 95/46/EC\nand Regulation (EC) No 45/2001 of the European Parliament and of the Council ( 2 ) are applicable to the\nprocessing of personal data for the purposes of this Directive. In particular, where personal data is processed\nfor the purposes of this Directive, the precise purpose should be specified, the relevant legal basis referred to, the\nrelevant security requirements laid down in Directive 95/46/EC complied with, and the principles of necessity,\nproportionality, purpose limitation and proportionate data retention period respected. Also, data protection by\ndesign and data protection by default should be embedded in all data processing systems developed and used\nwithin the framework of this Directive."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "The EU GDPR passages discuss the legal basis for processing, purpose limitation, and security requirements for personal data (chunk_ids bd84e63f5b622b73::6a8::d132, adb1a81b9cecaf8c::3ac::b555). The SG MAS passages discuss the 'same activities, same risk, same regulation' principle and risk-based capital frameworks for Stablecoin Issuers (SCS) and payment service providers (chunk_id 7c04f2a0bd85290a::449::02f2). The SG MAS text explicitly references the Payment Services Act and capital requirements, which are distinct from the data protection obligations described in the EU GDPR passages. There is no specific obligation in the SG MAS text that conflicts with the data protection obligations in the EU GDPR text; rather, the SG MAS text focuses on prudential and capital standards for cryptoasset exposures."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:29:53Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:0e0e09fb46aeab1bd483beb8", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "rationale": "The evidence for Regime A (AU_APRA_CPS234) focuses on APRA's Prudential Practice Guides, specifically CPG 230 (Operational Risk Management) and CPG 234 (Information Security), which provide guidance and views on sound practice for APRA-regulated entities. The evidence for Regime B (EU_EMD2) cites Directive (EU) 2022/2556 regarding digital operational resilience for the financial sector. While both regimes address operational resilience and risk management, the specific obligations and regulatory frameworks are distinct. The passages provided do not contain specific obligations in Regime A that directly conflict with specific obligations in Regime B; rather, they describe separate regulatory domains (Australian prudential practice vs. EU digital operational resilience directives)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:2e8df9afa9fe9cd7b3b462c0", "label": "non_conflict", "regime_a": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "SG_MAS_AML_GENERAL and SG_PSA_DPT are both MAS frameworks for AML/CFT supervision of DPT/payment-service providers in Singapore — PSN02 is the AML notice issued under the PSA, and the broader MAS AML framework operates alongside it. They reinforce each other within Singapore's coordinated regulatory architecture."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:15:12Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9ee7cb517956659bd100ec69", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "evidence_b": [{"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The EU MIFID2 passages regulate the conduct of investment firms, specifically regarding product governance, suitability assessments, and client communication (e.g., Article 1 and Article 25). The MAS TRM passages regulate the conduct of licensees under the Financial Services and Markets Act 2022, focusing on principles-based guidelines, risk assessments, and the application of the Fit and Proper (F&P) Guidelines. The obligations in MIFID2 regarding client suitability and information disclosure do not directly oppose the MAS TRM obligations regarding internal processes and risk assessments. The regimes regulate distinct aspects of financial services conduct, and there is no evidence of a specific obligation in one regime that creates an unavoidable conflict with a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:d199fb403716e745c5923a1d", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 234"}, "regime_b": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "ASIC crypto-asset guidance"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "ddcef7b1f5780c26::5d3::163e", "source_doc": "CPS_234_Information_Security.pdf", "page": null, "passage": "Prudential Standard CPS 234\nInformation Security\nObjectives and key requirements of this Prudential\nStandard\nThis Prudential Standard aims to ensure that an APRA-regulated entity takes\nmeasures to be resilient against information security incidents (including cyber-\nattacks) by maintaining an information security capability commensurate with\ninformation security vulnerabilities and threats.\nA key objective is to minimise the likelihood and impact of information security\nincidents on the confidentiality, integrity or availability of information assets,\nincluding information assets managed by related parties or third parties.\nThe Board of an APRA-regulated entity is ultimately responsible for ensuring that\nthe entity maintains its information security.\nThe key requirements of this Prudential Standard are that an APRA-regulated entity\nmust:\n clearly define the information security-related roles and responsibilities of the\nBoard, senior management, governing bodies and individuals;\n maintain an information security capability commensurate with the size and\nextent of threats to its information assets, and which enables the continued\nsound operation of the entity;\n implement controls to protect its information assets commensurate with the\ncriticality and sensitivity of those information assets, and undertake\nsystematic testing and assurance regarding the effectiveness of those controls;\nand\n notify APRA of material information security incidents.\nCPS 234 - 1\n\nAuthority"}], "evidence_b": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): APRA CPS 234 information security standard and ASIC's crypto-asset INFO 225 / RG 282 guidance operate in disjoint regulatory domains at the obligation level. Information security standard vs market-conduct crypto guidance — disjoint subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:a9fb8899dbfd50f706a776e9", "label": "non_conflict", "regime_a": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "evidence_b": [{"chunk_id": "6d8a84a9f3d6e9e4::480::ac46", "source_doc": "Guidelines_to_MAS_Notice_SFA04-N02_2025.pdf", "page": 5, "passage": "2 The FSM Sanctions Regulations include the regulations issued under section 192 read with sections 15(1)(b) and 219(d)\nof the FSM Act. Please refer to the following link for the FSM Sanctions Regulations:\nhttps://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions/regulations-for-targeted-financial-\nsanctions. Currently, the relevant FSM Sanctions Regulations are those relating to the Democratic People's Republic of\nKorea and Iran. concerns. Other support functions such as operations, human resource or\ntechnology also play a role to help mitigate the ML/TF risks that the CMI faces. The AML/CFT compliance function is typically the contact point regarding all\nAML/CFT issues for domestic and foreign authorities, including supervisory\nauthorities, law enforcement authorities and financial intelligence units.\n1-4-14 As the third line of defence, the CMI's internal audit function or an equivalent\nfunction plays an important role in independently evaluating the AML/CFT risk\nmanagement framework and controls for purposes of reporting to the audit\ncommittee of the CMI's board of directors, or a similar oversight body."}], "rationale": "SG_AML (MAS Notice 314 AML/CFT framework for life insurers) and SG_MAS_AML_GENERAL (MAS's broader AML/CFT supervisory framework — FSM Sanctions Regulations and SFA04-N02). Both are parts of MAS's coordinated AML/CFT architecture in Singapore."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:05:25Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:cbec7396aef09c2d9546a1c9", "label": "non_conflict", "regime_a": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "The EU regime regulates the solicitation of clients by third-country crypto-asset service providers (specifically prohibiting solicitation in the EU). The Singapore regime discusses the regulatory scope of securities custody services (SCS) and the potential for extending regulatory powers to foreign SCS, noting that extending powers may be better achieved through existing regulatory cooperation agreements. The passages describe distinct regulatory topics (solicitation vs. custody service scope) and do not impose conflicting obligations on the same activity. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:29:46Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:448cc53f51781cf93451544b", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "20d526d712753652::3ee::1555", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Harmonizing compliance standards for both financial institutions and payment\nservice providers is the best way to combat the global rise in money laundering,\nterrorism financing, and sanctions evasion, to plug gaps in overseeing transfers of\nvalue. Preventing SG-licensed entities from relying on foreign-licensed institutions 30 May 2025 | 40\nwith only money-transmitter-type licenses would be a useful step towards those\nlarger goals. Question 7. Reliance on Third Party. MAS seeks comments on the proposed amendments to\nthe other AML/CFT notices. No comment. Question 8. Correspondent Account Services. MAS seeks comments on whether the proposed\nrequirements for Correspondent Account Services set out in paragraph 5.6 would\nbe applicable to the sector. (Please refer to paragraph 12 of the draft FSM Notice). For correspondent account services, the licensee is relying on their client's standard\nof compliance in a manner similar to the \"Reliance on Third Party\" issues discussed\nin previous questions."}, {"chunk_id": "20d526d712753652::394::a11f", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "MAS seeks comments on the proposed duties of the CEO, directors, and partners\nof the licensee. MAS also seeks comments on the audit requirements.\n[Confidential]. Question 4. General comments. If you have comments on the measures proposed in parts 5-8,\nplease set them out in response to this question.\n[Confidential]. Question 5. Existing Customers. MAS seeks comments on the requirements for existing\ncustomers that were onboarded by the licensee prior to obtaining its licence. (Please refer to paragraph 6.54 and 6.55 of the draft FSM Notice).\n[Confidential]. Question 6. Reliance on Third Party. MAS seeks comments on whether third party reliance is\nappropriate for the sector. (Please refer to paragraph 12 of the draft FSM Notice). We do not have further comments. 30 May 2025 | 46\nQuestion 7. Reliance on Third Party. MAS seeks comments on the proposed amendments to\nthe other AML/CFT notices.\n[Confidential]."}], "rationale": "The evidence from AU_ASIC_CRYPTO focuses on the classification of digital assets as financial products and the licensing requirements for financial services providers under the Corporations Act (e.g., INFO 225, AFS licences). The evidence from SG_MAS_AML_GENERAL focuses on Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) obligations, specifically regarding the licensing of Digital Payment Token (DPT) service providers and the duties of CEOs and directors. The two regimes regulate distinct aspects of the digital asset ecosystem: one focuses on the financial product classification and licensing of financial services, while the other focuses on AML/CFT compliance and the licensing of payment service providers. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:41:45Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:f0314384a4380f48d19abe67", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "7e0886f59d1e36f5::90::5a8f", "source_doc": "Guidelines_to_MAS_Notice_1014_2025.pdf", "page": 49, "passage": "18 The website address as at 30 June 2025: https://www.police.gov.sg/Advisories/Crime/Commercial-Crimes/Suspicious-\nTransaction-Reporting-Office"}], "rationale": "The evidence from Regime A (AU_AML_CTF) outlines obligations for reporting suspicious matters and threshold transactions to the AUSTRAC CEO (chunk 254ca2d92d196180::2ac::a5fe). The evidence from Regime B (SG_PSA_GENERAL) provides a website address for the Suspicious Transaction Reporting Office in Singapore (chunk 7e0886f59d1e36f5::90::5a8f). The obligations in Regime A relate to Australian AML/CTF reporting requirements, while the evidence in Regime B is a reference to a Singaporean reporting body. The regimes regulate different jurisdictions and reporting channels, resulting in no overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:15:54Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:a210a91d8e809b3c78ea66d1", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "ba862e1f095bceac::1a6::1f0e", "source_doc": "FATF Recommendations 2012.pdf.coredownload.inline.pdf", "page": 79, "passage": "4. A country need not impose a separate licensing or registration system with respect to natural\nor legal persons already licensed or registered as financial institutions (as defined by the FATF\nRecommendations) within that country, which, under such license or registration, are\npermitted to perform VASP activities and which are already subject to the full range of\napplicable obligations under the FATF Recommendations."}], "rationale": "The EU MIFID2 passages regulate the conduct of investment firms, specifically regarding product governance, suitability assessments, and client information disclosure (e.g., Article 1 and Article 25). The INT_FATF_VASP passages define the scope of Virtual Asset Service Providers (VASPs) and AML/CFT obligations, noting that countries may extend their regimes beyond the minimum FATF standard and that existing licensed financial institutions performing VASP activities are already subject to FATF obligations. The regimes regulate distinct domains: MIFID2 governs investment services and conduct, while FATF governs AML/CFT and the definition of VASPs. There is no evidence of a specific obligation in MIFID2 that conflicts with a specific obligation in FATF; rather, the FATF guidance explicitly acknowledges that licensed financial institutions performing VASP activities are already subject to the full range of applicable obligations under the FATF Recommendations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:00:21Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:11623a06692a6eb65af6d09e", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}], "rationale": "The EU MICA Title IV EMT regime regulates the disclosure obligations of issuers of e-money tokens and asset-referenced tokens, including the content of crypto-asset white papers and notification requirements to competent authorities (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e). The INT FATF General regime provides high-level guidance on anti-money laundering and counter-terrorist financing (AML/CFT) risk assessment principles and the general framework for international standards (chunk_id fe52dd87e13dba41::261::59a4). The obligations in MICA relate to financial product disclosure and issuer liability, whereas FATF guidance relates to national risk assessment and AML/CFT policy. There is no specific obligation in the FATF regime that directly conflicts with or imposes a specific operational burden on the disclosure or liability obligations outlined in MICA. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:45:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:466d7db14f71480ef1f2379e", "label": "non_conflict", "regime_a": {"regime_id": "SG_MAS_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "a82833dc0f7ca903::5f1::735d", "source_doc": "Outsourcing_Guidelines_2018.pdf", "page": 25, "passage": "5.10.2 Material outsourcing arrangements with service providers located outside Singapore\nshould be conducted in a manner so as not to hinder MAS' efforts to supervise the Singapore\nbusiness activities of the institution (i.e., from its books, accounts and documents) in a timely\nmanner, in particular:\n(a) An institution should, in principle, enter into outsourcing arrangements only\nwith service providers operating in jurisdictions that generally uphold\nconfidentiality clauses and agreements.\n\n(b) An institution should not enter into outsourcing arrangements with service\nproviders in jurisdictions where prompt access to information by MAS or\nagents appointed by MAS to act on its behalf, at the service provider, may\nbe impeded by legal or administrative restrictions. An institution must at\nleast commit to retrieve information readily from the service provider\nshould MAS request for such information. The institution should confirm in\nwriting to MAS, that the institution has provided, in its outsourcing\nagreements, for MAS to have the rights of inspecting the service provider,\nas well as the rights of access to the institution and service provider's\ninformation, reports and findings related to the outsourcing arrangement,\nas set out in paragraph 5.9.\n(c) An institution should notify MAS if any overseas authority were to seek\naccess to its customer information or if a situation were to arise where the\nrights of access of the institution and MAS set out in paragraph 5.9, have\nbeen restricted or denied."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "The SG_MAS_OUTSOURCING regime focuses on the governance and supervision of third-party service providers, specifically requiring institutions to ensure MAS can access information and documents from overseas providers (chunk_id a82833dc0f7ca903::5f1::735d). The SG_PSA_DPT regime focuses on the licensing and AML/CFT obligations of entities providing digital payment token services (chunk_id 4b4c3c417dc293ba::185::f41d). The obligations in the outsourcing guidelines regarding information access and supervision are complementary to the licensing and regulatory oversight described in the DPT notice, rather than conflicting. The passages do not describe opposing rules or a lack of compliant path; instead, they address different aspects of the regulatory framework (governance vs. licensing/AML)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:02:33Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:6d179af91c8cd59d54193f0c", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::46d::fd1b", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "Binance is supportive of the redemption-related requirements. In general, five business\ndays should be sufficient to return the par value of the SCS to customers. However, given\nthat this is ultimately dependent on the availability of the relevant banking services,\nBinance would propose that this is aligned to the prevailing turnaround time provided by\nthe financial institution that the reserve assets are held with. Question 7. MAS seeks comments on whether the prudential requirements outlined in paragraph\n4.21 are risk proportionate. MAS welcomes suggestions on alternative approaches to\naddress the risks. Binance is supportive of the prudential requirements outlined in paragraph 4.21. 15 August 2023 | 23\nQuestion 10. MAS seeks comments on whether the scenario outlined in paragraph 4.22 is a likely\ndevelopment and whether the approaches outlined in paragraph 4.24 are feasible. MAS\nwelcomes suggestions on other approaches to address this issue. As per Q1, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction."}], "rationale": "The EU regime (Regime A) focuses on anti-money laundering (AML) obligations for crypto-asset service providers, specifically requiring them to accompany transfers of funds and crypto-assets with information on the payer and payee to ensure traceability for AML/CFT purposes (chunk_id=c0300673081f7232::279::1918). The Singapore regime (Regime B) focuses on prudential treatment and capital requirements for stablecoin issuers and related entities, aiming to ensure market stability and consumer protection through a risk-based framework (chunk_id=7c04f2a0bd85290a::46d::fd1b). The obligations are distinct: one is a compliance/AML requirement, and the other is a financial stability/prudential requirement. There is no evidence in the provided passages of a specific obligation in one regime pushing against a specific obligation in the other; rather, they regulate different aspects of the crypto-asset ecosystem."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:20:08Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:08593f2a27b9697b4c2f1a98", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "The FATF passages discuss global AML/CFT standards and guidance for Virtual Asset Service Providers (VASPs), specifically regarding digital identity and red flag indicators (chunk 85240528438654b9::396::417b). The MAS passages focus on Singapore's domestic prudential framework for cryptoassets, including capital requirements and stablecoin issuers (chunk 7c04f2a0bd85290a::449::02f2). The obligations are distinct: FATF sets international AML/CFT standards, while MAS sets domestic prudential standards. There is no specific obligation in FATF that pushes against a specific obligation in MAS; rather, they regulate different aspects of the crypto ecosystem (compliance vs. capital adequacy)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:24:56Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:291e3291a4ee6e216746001b", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "SG_MAS_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "a82833dc0f7ca903::5f1::735d", "source_doc": "Outsourcing_Guidelines_2018.pdf", "page": 25, "passage": "5.10.2 Material outsourcing arrangements with service providers located outside Singapore\nshould be conducted in a manner so as not to hinder MAS' efforts to supervise the Singapore\nbusiness activities of the institution (i.e., from its books, accounts and documents) in a timely\nmanner, in particular:\n(a) An institution should, in principle, enter into outsourcing arrangements only\nwith service providers operating in jurisdictions that generally uphold\nconfidentiality clauses and agreements.\n\n(b) An institution should not enter into outsourcing arrangements with service\nproviders in jurisdictions where prompt access to information by MAS or\nagents appointed by MAS to act on its behalf, at the service provider, may\nbe impeded by legal or administrative restrictions. An institution must at\nleast commit to retrieve information readily from the service provider\nshould MAS request for such information. The institution should confirm in\nwriting to MAS, that the institution has provided, in its outsourcing\nagreements, for MAS to have the rights of inspecting the service provider,\nas well as the rights of access to the institution and service provider's\ninformation, reports and findings related to the outsourcing arrangement,\nas set out in paragraph 5.9.\n(c) An institution should notify MAS if any overseas authority were to seek\naccess to its customer information or if a situation were to arise where the\nrights of access of the institution and MAS set out in paragraph 5.9, have\nbeen restricted or denied."}], "rationale": "The EU MICA Title IV EMT passages regulate the content and liability of crypto-asset white papers for issuers of e-money tokens (e.g., Article 51 notification requirements and Article 52 liability for misleading information). The SG MAS Outsourcing passages regulate the conduct of outsourcing arrangements with service providers, specifically regarding information access and supervision (e.g., Clause 5.10.2). The obligations in the EU regime relate to the transparency of the token offering and issuer liability, while the obligations in the SG regime relate to the operational management of third-party service providers. These are distinct regulatory domains; the EU obligations do not impose specific requirements on the SG outsourcing conduct of a service provider, nor do the SG outsourcing requirements impose specific content obligations on the crypto-asset white paper. Therefore, the regimes do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:6c2812a10569e4265fca00af", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}, {"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "AU_APRA_CPS230 (APRA Prudential Standard CPS 230 — Operational Risk Management) and MAS_TRM (MAS Technology Risk Management Guidelines). Both implement operational-resilience / technology-risk frameworks for regulated financial institutions in their jurisdictions. Reinforcing concerns."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:12:52Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:a822c45c687e68e1fded4264", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "The evidence for AU_APRA_CPS230 focuses on operational resilience, business continuity, and the management of service providers to ensure critical operations continue through disruptions (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c). The evidence for SG_AML focuses on training officers and employees on AML/CFT laws, suspicious transaction reporting, and internal policies (chunk_id 3d521e61e49aaf46::38f::e615). These obligations regulate distinct aspects of an entity's operations: one ensures resilience against operational disruptions, while the other ensures compliance with financial crime prevention laws. There is no specific obligation in CPS 230 that conflicts with the AML training requirements in MAS Notice 314."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:39:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:a5c44ff260acfa06849e3147", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::320::7b46", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 3, "passage": "(19) In order to foster administrative cooperation with non-Union jurisdictions, crypto-asset operators that meet certain\nconditions should be allowed to solely report information on crypto-asset users resident in the Union to the tax\nauthorities of a non-Union jurisdiction insofar as the reported information corresponds to the information set out\nin this Directive and insofar as there is an effective qualifying competent authority agreement in place with such\nnon-Union jurisdiction. The qualified non-Union jurisdiction would in turn communicate such information to the\ntax administrations of the Member States where the crypto-asset users are resident. Where appropriate, that\nmechanism should be enabled to prevent corresponding information from being reported and transmitted more\nthan once."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "The EU DAC8 regime focuses on the automatic exchange of tax information between Member States and non-Union jurisdictions (e.g., Singapore) regarding crypto-asset users (Recital 19, chunk_id c0300673081f7232::320::7b46). In contrast, the Singapore PSA DPT regime (MAS Notice PSN02) regulates the licensing and Anti-Money Laundering/Counter-Terrorism Financing (AML/CFT) obligations of Digital Payment Token service providers operating in Singapore (Clause 1.1, chunk_id 4b4c3c417dc293ba::185::f41d). The obligations in DAC8 are administrative and tax-reporting in nature, whereas the obligations in PSA DPT are regulatory and compliance-focused for service providers. The regimes regulate different aspects of the crypto-asset ecosystem (tax reporting vs. licensing and AML/CFT controls) and do not impose conflicting obligations on the same specific action."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:be84c32a63fc42113ec00ca7", "label": "conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "SG_FSMA_DTSP (Singapore DTSP licensing under FSM Act — extraterritorial reach on persons providing digital-token services 'in or from Singapore') and AU_AML_CTF (Australian AML/CTF Act — reporting-entity perimeter for businesses providing designated services). Whether an AU-based entity falls within SG DTSP extraterritorial scope turns on FACTS about the entity's place of operation, customer base, and service delivery channels — not resolvable from the rules alone. The two regimes can both apply or only one, depending on those facts.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:16Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:03:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:4598773b0eb574271d33cb74", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}], "rationale": "The evidence for AU_ATO_CRYPTO focuses on token mapping, tax compliance, and specific regulatory guidance for superannuation and construction contracts (chunk_ids e6bb47e92e88e16c::567::36c4, bab9bcdb09e99b2d::34b::a4e6, bab9bcdb09e99b2d::40b::de13). The evidence for INT_FATF_GENERAL outlines general principles for assessing money laundering and terrorist financing risks at the national level (chunk_ids fe52dd87e13dba41::261::59a4, 75b61beed88910f9::4ad::debc). The passages describe distinct regulatory domains: one focuses on Australian tax and crypto asset regulation, while the other provides international standards for AML/CFT risk assessment. There is no specific obligation in the AU_ATO_CRYPTO passages that conflicts with the general principles in the INT_FATF_GENERAL passages."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:40:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:3264fb3a94735227a3c04be1", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "Regime A (AU_APRA_CPS234) is a Prudential Practice Guide regarding Operational Risk Management and Information Security for APRA-regulated entities. Regime B (SG_FSMA_DTSP) is a set of guidelines and consultation responses regarding the licensing and regulation of Digital Token Service Providers under the Singapore Financial Services and Markets Act. The obligations in Regime A relate to internal prudential risk management and information security standards for financial institutions. The obligations in Regime B relate to the licensing, conduct, and AML/CFT compliance of digital token service providers. The two regimes regulate distinct domains (general prudential risk management vs. specific digital token sector licensing and conduct), and there is no specific obligation in Regime A that conflicts with a specific obligation in Regime B."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:44:02Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:41bf9b8c2f6cab6c474fa79d", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "The EU_NIS2 passage discusses the preparation of technical standards and guidelines for access controls and ICT security measures (chunk 3c9eb3a25c93f394::474::4786). The SG_FSMA_DTSP passage outlines the licensing requirements and definitions for Digital Token Service Providers (DTSPs) under the FSM Act, including the requirement to hold a licence to conduct digital token services in Singapore (chunk cc1be49e9cf8c821::2f4::ea8f). The obligations in the SG regime relate to licensing and operational conduct for service providers, while the EU regime focuses on the technical security standards for access controls. These are distinct regulatory domains; the SG licensing requirements do not impose specific technical access control mandates that conflict with the EU's general framework for ICT security standards."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:13:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:fa5582abd2084a4eb0b62b15", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}, {"chunk_id": "254ca2d92d196180::377::d0c6", "source_doc": "AML_CTF_Act_2006.pdf", "page": 124, "passage": "Part 3 Reporting obligations\nDivision 3 Threshold transactions\nSection 43\nDivision 3-Threshold transactions\n43 Reports of threshold transactions\nScope\n(1) This section applies to a reporting entity if:\n(a) the reporting entity commences to provide, or provides, a\ndesignated service to a customer; and\n(b) the provision of the service involves a threshold transaction. Report\n(2) The reporting entity must, within 10 business days after the day on\nwhich the transaction takes place, give the AUSTRAC CEO a\nreport of the transaction. (3) A report under subsection (2) must:\n(a) be in the approved form; and\n(b) contain such information relating to the transaction as is\nspecified in the AML/CTF Rules. Note 1: For additional rules about reports, see section 244. Note 2: Section 49 deals with the provision of further information, and the\nproduction of documents, by the reporting entity."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}, {"chunk_id": "018117ef1e757630::4b5::9ef5", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Guidelines\n• MAS' surveillance efforts are • Existing VASPs operating in\nfocused on: (a) detecting and Singapore were required to notify\nLicensing\ndeterring unlicensed DPT activities MAS and submit licence\nSurveillance and\nin Singapore; and (b) leveraging applications by 28 Jul 2020.\ndata and blockchain analytics to Supervision\nidentify higher risk entities. • Applicants expected to\ndemonstrate understanding and\nability to mitigate ML/TF risks. Slide 5 (III) AML/CFT requirements for DPT sector\nAML/CFT requirements for digital payment token (DPT) service in Singapore\n• AML/CFT requirements are set out in MAS Notice PSN02 (issued 5 Dec 2019) and Guidelines to PSN02 (issued on 16 Mar 2020). Amendments to the Payment Services Act were passed in Parliament in Jan 2021 to expand the scope of DPT services and\nfurther updates to Notice PSN02 and Guidelines are in train to apply AML/CFT requirements to the newly scoped-in DPT services.\n• Entities that (a) deal in DPT; (b) facilitate the exchange of DPT; (c) facilitate the transmission of DPT; (d) and/or provide custodian\nwallet services, will therefore be required to be licensed as DPT service providers, and comply with the AML/CFT requirements."}], "rationale": "Regime A (AU_TTR_THRESHOLD) regulates the reporting of physical cash transfers exceeding A$10,000 to AUSTRAC. Regime B (SG_PSA_DPT) regulates the licensing and AML/CFT obligations of entities providing Digital Payment Token (DPT) services in Singapore. The obligations in Regime A relate to physical currency reporting thresholds, while Regime B focuses on the licensing and supervision of digital asset service providers. The passages confirm that these regimes govern distinct transaction types (physical cash vs. digital tokens) and distinct regulatory domains (AUSTRAC reporting vs. MAS licensing), with no evidence of a direct obligation clash between the two."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:ff3742d3e20b984d1eaef95a", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU AML/CTF (AUSTRAC guidance)"}, "regime_b": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU TTR Threshold"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}], "evidence_b": [{"chunk_id": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): AUSTRAC AML/CTF operational guidance and AUSTRAC TTR $10k cash threshold reporting are designed to coexist — obligations apply cumulatively without collision. The TTR regime is a specific reporting duty within the broader AUSTRAC AML/CTF framework — same regime, different granularity. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:729fd6f86c08f33e85da5686", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::46d::fd1b", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "Binance is supportive of the redemption-related requirements. In general, five business\ndays should be sufficient to return the par value of the SCS to customers. However, given\nthat this is ultimately dependent on the availability of the relevant banking services,\nBinance would propose that this is aligned to the prevailing turnaround time provided by\nthe financial institution that the reserve assets are held with. Question 7. MAS seeks comments on whether the prudential requirements outlined in paragraph\n4.21 are risk proportionate. MAS welcomes suggestions on alternative approaches to\naddress the risks. Binance is supportive of the prudential requirements outlined in paragraph 4.21. 15 August 2023 | 23\nQuestion 10. MAS seeks comments on whether the scenario outlined in paragraph 4.22 is a likely\ndevelopment and whether the approaches outlined in paragraph 4.24 are feasible. MAS\nwelcomes suggestions on other approaches to address this issue. As per Q1, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction."}, {"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "AU_APRA_CPS230 (APRA Prudential Standard CPS 230 — Operational Risk Management for AU-regulated entities) and SG_MAS_PRUDENTIAL_CRYPTO (MAS's risk-based capital framework for SCS issuers). Both prudential frameworks but addressing different specific concerns — CPS 230 is operational-risk and service-provider management; SG's SCS framework is capital adequacy for stablecoin issuers. Different jurisdictions and mechanisms; no direct obligation conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:13:11Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:64221a630f1524b74f318f43", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "ba862e1f095bceac::1a6::1f0e", "source_doc": "FATF Recommendations 2012.pdf.coredownload.inline.pdf", "page": 79, "passage": "4. A country need not impose a separate licensing or registration system with respect to natural\nor legal persons already licensed or registered as financial institutions (as defined by the FATF\nRecommendations) within that country, which, under such license or registration, are\npermitted to perform VASP activities and which are already subject to the full range of\napplicable obligations under the FATF Recommendations."}], "rationale": "The EU PSD2 passages regulate the technical security of payment transactions, specifically mandating strong customer authentication (SCA) and the protection of personalised security credentials (chunk_ids adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b). The INT_FATF_VASP passages regulate the AML/CFT obligations of Virtual Asset Service Providers (VASPs) and clarify that countries may extend their regimes beyond the FATF minimum standard (chunk_ids 85240528438654b9::1cd::07d7, ba862e1f095bceac::1a6::1f0e). The regimes regulate distinct domains: one focuses on the technical authentication of payment initiation and security credentials, while the other focuses on the regulatory licensing and AML/CFT obligations of entities providing services for virtual assets. There is no evidence of a specific obligation in PSD2 that directly conflicts with a specific obligation in FATF regarding VASPs."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:b6c41af3537b4216fa349e5b", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "rationale": "AU_AML_CTF (Australian AML/CTF Act — AUSTRAC reporting framework) and EU_AMLA (EU's new Anti-Money Laundering Authority under AMLD6 — Article 62-63 supervisory cooperation). Both implement AML/CFT supervisory architecture in their jurisdictions consistent with FATF standards. Reinforcing."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:51f0eabd3db0ee08e2159166", "label": "conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + Transfer of Funds Regulation"}, "regime_b": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "GDPR"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}, {"chunk_id": "d7502c011527b67c::29c::b792", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 23, "passage": "Article 17\nTransfers of crypto-assets with missing or incomplete information on the originator or the beneficiary\n1.\nThe crypto-asset service provider of the beneficiary shall implement effective risk-based procedures, including\nprocedures based on the risk-sensitive basis referred to in Article 13 of Directive (EU) 2015/849, for determining\nwhether to execute, reject, return or suspend a transfer of crypto-assets lacking the required complete information\non the originator and the beneficiary and for taking the appropriate follow-up action.\nEN\nL 150/23\n\nWhere the crypto-asset service provider of the beneficiary becomes aware that the information referred to in"}, {"chunk_id": "d7502c011527b67c::1a0::faa6", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 24, "passage": "Article 19\nRetention of information on the originator and the beneficiary accompanying the transfer\nIntermediary crypto-asset service providers shall ensure that all the information received on the originator and the\nbeneficiary that accompanies a transfer of crypto-assets is transmitted with the transfer and that records of such\ninformation are retained and made available on request to the competent authorities."}], "evidence_b": [{"chunk_id": "bd84e63f5b622b73::4a6::7573", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 1, "passage": "Consistent and\nhomogenous application of the rules for the protection of the fundamental rights and freedoms of natural\npersons with regard to the processing of personal data should be ensured throughout the Union. Regarding the\nprocessing of personal data for compliance with a legal obligation, for the performance of a task carried out in\nthe public interest or in the exercise of official authority vested in the controller, Member States should be\nallowed to maintain or introduce national provisions to further specify the application of the rules of this\nRegulation. In conjunction with the general and horizontal law on data protection implementing Directive\n95/46/EC, Member States have several sector-specific laws in areas that need more specific provisions. This\nRegulation also provides a margin of manoeuvre for Member States to specify its rules, including for the\nprocessing of special categories of personal data ('sensitive data'). To that extent, this Regulation does not exclude\nMember State law that sets out the circumstances for specific processing situations, including determining more\nprecisely the conditions under which the processing of personal data is lawful."}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "bd84e63f5b622b73::5e6::a9fd", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 62, "passage": "Article 46\nTransfers subject to appropriate safeguards\n1. In the absence of a decision pursuant to Article 45(3), a controller or processor may transfer personal data to a\nthird country or an international organisation only if the controller or processor has provided appropriate safeguards,\nand on condition that enforceable data subject rights and effective legal remedies for data subjects are available.\n2. The appropriate safeguards referred to in paragraph 1 may be provided for, without requiring any specific authoris\nation from a supervisory authority, by:\n(a) a legally binding and enforceable instrument between public authorities or bodies;\n(b) binding corporate rules in accordance with Article 47;\n(c) standard data protection clauses adopted by the Commission in accordance with the examination procedure referred\nto in Article 93(2);\n(d) standard data protection clauses adopted by a supervisory authority and approved by the Commission pursuant to\nthe examination procedure referred to in Article 93(2);\n(e) an approved code of conduct pursuant to Article 40 together with binding and enforceable commitments of the\ncontroller or processor in the third country to apply the appropriate safeguards, including as regards data subjects'\nrights; or\n(f) an approved certification mechanism pursuant to Article 42 together with binding and enforceable commitments of\nthe controller or processor in the third country to apply the appropriate safeguards, including as regards data\nsubjects' rights.\n3."}], "rationale": "TFR Articles 14, 17 and 19 require the originator's and beneficiary's CASPs to collect, transmit and retain identifying personal data (name, account/wallet, address, ID number, date and place of birth) for every crypto-asset transfer and to retain that information for later production to competent authorities. GDPR Article 5(1)(b)-(c) and Articles 44–49 push in the opposite direction: data minimisation, purpose limitation, and tight controls on cross-border transfers of personal data to third countries. The tension is operationally resolvable rather than structural because GDPR itself recognises 'compliance with a legal obligation' as a lawful basis (Art. 6(1)(c)) and the TFR is precisely such an EU legal obligation; cross-border transmission to non-EEA counterparties is resolvable via the Chapter V instruments (adequacy decision, SCCs, BCRs, derogations). The cost is real: CASPs must design retention limits, onward-sharing controls and transfer-impact assessments rather than ignoring either regime.", "compliant_paths": ["Rely on GDPR Art. 6(1)(c) (legal obligation) as the lawful basis for collection and intra-EU transmission of TFR-mandated fields.", "For transmission of personal data to a non-EEA counterparty CASP, layer SCCs (Art. 46(2)(c)) plus a transfer-impact assessment on top of the TFR obligation.", "Apply Art. 5(1)(e) by setting an explicit retention period for TFR records (e.g. five years post-relationship, consistent with AMLD/AMLR)."], "out_of_scope_assumptions": ["Both parties are commercial CASPs subject to MiCA; consumer-protection overlays under EU consumer law are not analysed.", "The transfer is between two human or legal-person customers; transactions involving designated persons (sanctions) are not separately treated here."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:59:05Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:a136c8a851834f76af562cac", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "rationale": "The AU_TRAVEL_RULE passages describe Australia's regulatory framework for remittance networks and virtual asset service providers, including the current status of the FATF Travel Rule and AML/CTF obligations. The EU_REVERSE_SOLICITATION passages describe a specific exemption under MiCA for third-country firms providing crypto-asset services to clients who initiate the relationship (reverse solicitation). The two regimes regulate different aspects of the crypto-asset industry: one focuses on the implementation of the FATF Travel Rule and AML/CTF obligations for service providers, while the other focuses on the marketing and authorization requirements for third-country firms interacting with EU clients. There is no specific obligation in the AU_TRAVEL_RULE that conflicts with the reverse solicitation exemption described in the EU passages. Therefore, the regimes are in non_conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:99076394db99f05f7df530fd", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EMD2"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}], "evidence_b": [{"chunk_id": "6bbad50f6b09cc9d::27e::94d4", "source_doc": "EMD2_Directive_EU_2009-110.pdf", "page": 6, "passage": "Article 4\ntution to hold an amount of own funds which is up to 20 %\nInitial capital higher than the amount which would result from the appli\ncation of the relevant method in accordance with paragraph\nMember States shall require electronic money institutions to\n2, or permit the electronic money institution to hold an\nhold, at the time of authorisation, initial capital, comprised of\namount of own funds which is up to 20 % lower than the\nthe items set out in Article 57(a) and (b) of Directive\namount which would result from the application of the\n2006/48/EC, of not less than EUR 350 000.\nrelevant method in accordance with paragraph 2."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU DORA ICT operational-resilience regulation and EU EMD2 e-money-institution directive are designed to coexist — obligations apply cumulatively without collision. EMIs are EU financial entities under DORA — ICT-resilience regime applies cumulatively with EMD2 authorisation. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-18T11:48:14Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:e04f96f8d1952a9b4e4bb32f", "label": "conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "550958b067dc6726::41f::546c", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 24, "passage": "3.1 Standard AFSL Obligations\nAustralian financial services licence\n(a) A platform provider must hold an AFSL authorising them to issue and deal in digital asset facilities.\n(b) A platform provider is exempt from holding an AFSL for digital asset facilities if:\n(i) the total value of platform entitlements held by any one client of the platform provider does\nnot exceed $1,500 at any one time; and\n(ii) the total amount of assets held by the platform provider does not exceed $5 million at any\ntime.\nInfo Box 3 Low value exemption\nThe risks with digital asset facilities are correlated to the size and scale of the asset holding role of\nthe platform provider. Accordingly, a 'low-value facility' exemption would be introduced, similar to\nthe 'low value facility' exemption for non-cash payment facilities. It would apply to digital asset\nfacilities holding less than $1,500 per customer and less than $5 million in total.40 This exemption\nis intended to allow for innovation and experimentation in the early stages of developing a novel\nservice offering."}, {"chunk_id": "550958b067dc6726::74a::7ef1", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 26, "passage": "46 For information on ASIC's interpretation of this obligation, see ASIC PF 209 Australian financial services\nlicence conditions\nLicensing digital asset intermediaries | 23\n\n(vi) having the financial,47 technological, and human resources to carry out and supervise the\nfinancial service covered by the AFSL,\n(vii) having a dispute resolution system48 and compensation arrangements for retail clients for\nloss or damage suffered due to breaches of obligations, and\n(viii) maintaining a risk management system.\nFinancial requirements\n(g) A platform provider must meet:\n(i) the standard solvency and positive net asset requirements,49\n(ii) the standard cash needs requirement, and\n(iii) a net tangible assets (NTA) requirement for holding cash or cash equivalents and holding\nliquid assets of at least:\n• 0.5 per cent of the value of the facility (if using a sub-custodian digital asset facility that\nhas $5m NTA),50 or\n• $5 million (if performing the custody function).\nInfo Box 6 Financial requirements\nAFSL holders have obligations to meet 'financial requirements'. These requirements are typically\ntailored for different financial products through ASIC legislative instruments. The NTA obligation is\nto address the costs of orderly wind-up in the event the provider fails.51\nA key issue with digital assets is concentration risk (see Info Box 11 Additional Standards for token\nholders). The proposed financial requirements balance the need to avoid concentration of digital\nassets among a small number of custodians with the need to ensure robust NTA. It sets the\nrequired level of NTA at the greater of $5 million or 0.5% of the value of the assets held by the\nfacility.52 This arrangement ensures that as a facility expands, and the operational risk exposure of\nthe platform provider grows, the provider will maintain a corresponding level of financial\nresources."}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "AU_ASIC_AFSL (AU AFSL framework for financial-services entities) and SG_FSMA_DTSP (Singapore FSM Act 2022 Part 9 — DTSP licensing with extraterritorial reach). When an entity provides digital-token services in or from Singapore AND offers crypto-as-financial-product to AU clients, both licensing regimes apply. Operationally resolvable through dual authorisation; the SG DTSP framework explicitly contemplates extraterritorial scope on persons operating 'in or from' Singapore.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:28:06Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:16:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:f1a68824dbee84ebaacf63dc", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The EU_MAR regime regulates market abuse, insider dealing, and market manipulation (chunk 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The MAS_TRM regime, as evidenced by the 'Response to Feedback Received' (chunk 20d526d712753652::401::f956), focuses on the application of principles-based guidelines (TRM Guidelines) to licensees and their risk assessments. The passages describe distinct regulatory domains: one governing conduct of business and market integrity (EU_MAR), and the other governing the application of industry best practices and risk management frameworks to licensees (MAS_TRM). There is no evidence of a specific obligation in EU_MAR that creates a conflict with a specific obligation in MAS_TRM."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:05:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:68f2f86cdba1a4e2cfdfc728", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "The EU_MICA_RTS passages describe the development of regulatory technical standards (RTS) and guidelines for crypto-asset service providers (CASPs) and asset-referenced tokens, focusing on notification requirements and acquisition assessments (chunk_ids c51ad46265cea4e5::2f5::4513 and c51ad46265cea4e5::361::e378). The SG_AML passages focus on AML/CFT training obligations for direct life insurers and general AML/CFT principles for banks (chunk_ids 3d521e61e49aaf46::38f::e615 and 39886a6842407c92::356::ee53). The obligations in MiCA regarding crypto-asset service provision do not overlap with the AML/CFT obligations for life insurers or banks in Singapore. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:35:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:aabff688dc9e094c1cbf89d3", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "rationale": "The AU_TREASURY_DAP passages discuss the Australian government's 'token mapping' exercise and the development of a licensing framework for crypto asset service providers (chunk_id=d75262e404517e0c::47b::7c9f). The EU_NIS2 passages reference Directive (EU) 2022/2556, which concerns digital operational resilience for the financial sector (chunk_id=85307f9e2a040982::14a::134d). The obligations in the Australian regime relate to the licensing and perimeter demarcation of crypto asset service providers, while the EU regime addresses operational resilience. These are distinct regulatory domains; the Australian licensing framework does not impose specific obligations that conflict with the EU's digital operational resilience requirements."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.84, "record_type": "non_conflict", "pair_id": "non_conflict:d09fb51c597126578dc0f9cf", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + Transfer of Funds Regulation"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "MAS AML/CFT Notices"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}, {"chunk_id": "d7502c011527b67c::1a0::faa6", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 24, "passage": "Article 19\nRetention of information on the originator and the beneficiary accompanying the transfer\nIntermediary crypto-asset service providers shall ensure that all the information received on the originator and the\nbeneficiary that accompanies a transfer of crypto-assets is transmitted with the transfer and that records of such\ninformation are retained and made available on request to the competent authorities."}], "evidence_b": [{"chunk_id": "39886a6842407c92::319::727a", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 31, "passage": "11.8 All wire transfer originator and beneficiary information collected by the ordering institution\nshall be documented.\n\n11.9 Where the ordering institution is unable to comply with the requirements in paragraphs\n11.3 to 11.8, it shall not execute the wire transfer.\nResponsibility of the Beneficiary Institution\n\n11.10 A bank that is a beneficiary institution shall take reasonable measures, including post-\nevent monitoring or real-time monitoring where feasible, to identify cross-border wire\ntransfers that lack the required wire transfer originator or required wire transfer beneficiary\ninformation.\n\n11.11 For cross-border wire transfers, a beneficiary institution shall identify and verify the\nidentity of the wire transfer beneficiary if the identity has not been previously verified."}, {"chunk_id": "f5d3fd73849ee27c::3b9::4f9f", "source_doc": "MAS_Notice_PSN01_2024-04-02.pdf", "page": 36, "passage": "15.10 All wire transfer originator and beneficiary information collected by the ordering institution\nshall be documented.\n\n15.11 Where the ordering institution is unable to comply with the requirements in paragraphs\n15.3 to 15.10, it shall not execute or arrange for the wire transfer.\n\nResponsibility of the Beneficiary Institution\n\n15.12 A payment service provider that is a beneficiary institution shall take reasonable\nmeasures, including post-event monitoring or real-time monitoring where feasible, to\nidentify cross-border wire transfers that lack the required wire transfer originator or\nrequired wire transfer beneficiary information.\n\n15.13 For cross-border wire transfers where the beneficiary institution pays out funds in cash or\ncash equivalent to the wire transfer beneficiary in Singapore, a beneficiary institution shall\nidentify and verify the identity of the wire transfer beneficiary if the identity has not been\npreviously verified."}], "rationale": "The EU TFR and MAS AML/CFT Notices both implement FATF Recommendation 16 (the wire-transfer / VASP travel rule). They apply to different regulated populations in different jurisdictions and use different statutory vehicles (EU Regulation vs MAS Notice). For a single transaction crossing EU↔SG, both regimes apply at their respective ends — the EU CASP to its TFR obligations, the MAS-regulated FI to its Notice obligations — and the obligations are designed to be interoperable (matching originator/beneficiary data sets, matching threshold concepts). This is not a conflict; it is the cross-jurisdictional implementation of the same FATF standard.", "would_conflict_if": ["Data-field specifications diverged in a way that would force one side to omit a field the other requires (e.g. MAS dropping wallet-address requirement); current text shows convergence."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:d09fb51c597126578dc0f9cf", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "c4024f4c4c1616cc::23d::700a", "source_doc": "AMLR_Regulation_EU_2024-1624.pdf", "page": 2, "passage": "(7) Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers\nof funds and certain crypto-assets and amending Directive (EU) 2015/849 (OJ L 150, 9.6.2023, p. 1).\n\n(8) Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing the Authority for\nAnti-Money Laundering and Countering the Financing of Terrorism and amending Regulations (EU) No 1093/2010, (EU)\nNo 1094/2010 and (EU) No 1095/2010 (OJ L, 2024/1620, 19.6.2024, http://data.europa.eu/eli/reg/2024/1620/oj)."}, {"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}, {"chunk_id": "39886a6842407c92::356::ee53", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 6, "passage": "3.1 This Notice is based on the following principles, which shall serve as a guide for all banks\nin the conduct of their operations and business activities:\n(a) A bank shall exercise due diligence when dealing with customers, natural persons\nappointed to act on the customer's behalf, connected parties of the customer and\nbeneficial owners of the customer.\n(b) A bank shall conduct its business in conformity with high ethical standards, and\nguard against establishing any business relations or undertaking any transaction,\nincluding a digital token transaction, that is or may be connected with, or facilitates\nor may facilitate money laundering or terrorism financing.\n(c) A bank shall, to the fullest extent possible, assist and cooperate with the relevant\nlaw enforcement authorities in Singapore to prevent money laundering and\nterrorism financing."}], "rationale": "EU_AMLR_TFR (EU AML regulation extending AML/CFT framework to CASPs and requiring information accompanying crypto transfers) and SG_AML (MAS Notice 314 on AML/CFT for life insurers and similar MAS notices for banks). Both implement AML/CFT obligations in their jurisdictions consistent with FATF standards. The obligations reinforce each other; entities operating across both jurisdictions face complementary AML duties."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:44:09Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:8cb90c0bcb3faf71baa16b74", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "regime_b": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "evidence_b": [{"chunk_id": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}], "rationale": "The Basel III passage (chunk 32afd37cade34f84::34b::8d30) discusses the exclusion of fiduciary assets from the leverage ratio exposure measure based on accounting standards (IFRS 9/10). The IRAS passage (chunk abc2247bc6415d1d::41e::b184) discusses the GST treatment of digital payment tokens, specifically that they are exempt from GST. The obligations relate to banking capital calculations and tax treatment of digital assets, respectively. There is no specific obligation in the Basel III framework that pushes against a specific obligation in the IRAS tax guide regarding the same transaction or asset type. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:31:07Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:286d381bae9a92de891c31b1", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::284::b4a8", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 38, "passage": "94. The FATF Standards, including the definitions of virtual assets and VASPs, represent\na minimum standard for countries to introduce. In line with the RBA, countries may\nchoose to extend their AML/CFT regimes to include other digital assets and entities,\nbeyond the FATF definition of virtual asset and VASP. Such a determination should\nbe made on the basis of a ML/TF risk assessment, with consideration of the\nchallenges associated with regulatory divergence.\n\nUPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS  37\nPART THREE:\nAPPLICATION OF FATF STANDARDS TO COUNTRIES AND\nCOMPETENT AUTHORITIES"}], "evidence_b": [{"chunk_id": "14cb9eb911d15322::42b::fe23", "source_doc": "2023_Response_PS_Regulations_Amendments.pdf", "page": 22, "passage": "LTD Question 1. MAS seeks comments on the proposed amendments to the Payment Services\nRegulations.\n1. The term safeguarding institution needs to be defined for the purposes of\nRegulation16C. Since DPTSP can self custodize it would be good to have a clear\ndefinition of safeguarding customer's assets. The term \"safeguarding\" is also not\nused/defined in Securities and Futures Act or in the Securities and Futures\n(licensing and conduct of business) regulations in the context of customer\nassets.\n2. It is not clear in these amendments whether a PSA license is a blanket license\nthat will allow the licensee to conduct all of the digital payment token services\n(i.e. broking dealing in DPT, DPT Exchange, DPT Custody) under one PSA license 2 April 2024 | 26\nor would a licensee be granted a PSA license for specific digital payment token\nservices? Trying to draw an analogy here from the Capital Market Services\nLicense (CMSL) where each CMSL holder is given a license outlining the activities\nthat they can do under the CMSL license.\n8 Interactive Brokers Question 1."}], "rationale": "The FATF VASP passages discuss the global definition of Virtual Assets (VA) and Virtual Asset Service Providers (VASP), and the application of FATF Standards to financial institutions conducting VASP activities (chunk_ids 85240528438654b9::1cd::07d7, 85240528438654b9::284::b4a8). The Singapore PSA passages discuss the licensing of Digital Payment Token Service Providers (DPTSP) under the Payment Services Act, specifically regarding the definition of 'safeguarding institution' and the scope of a PSA license (chunk_id 14cb9eb911d15322::42b::fe23). The regimes regulate the same underlying subject matter (VASPs/DPTSP) but from different jurisdictional perspectives. The FATF text indicates that countries may extend their AML/CFT regimes beyond the minimum FATF definition of VASP (chunk_id 85240528438654b9::284::b4a8), which is consistent with Singapore's specific licensing framework for DPTSP. There is no evidence of a direct obligation in one regime that contradicts or invalidates the other; rather, they represent aligned regulatory approaches to the same sector."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:d2209d8a6c05bca63200b6e0", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}], "rationale": "FATF_R16 (FATF Recommendation 16 — travel rule for VAs/VASPs) and INT_FATF_GENERAL (FATF general AML/CFT framework). R16 is part of the broader FATF framework; both operate together as parts of the same FATF Recommendations. Aligned by design."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:40:58Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:d70f2d22c280f731905030e4", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "rationale": "The evidence from the AU_ATO_CRYPTO regime focuses on the taxation of crypto assets and the government's reform agenda (chunk_id e6bb47e92e88e16c::567::36c4). The evidence from the EU_AMLA regime describes the institutional framework for Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) and the establishment of the Authority for AMLA (chunk_id df546f2364aaf9e2::25a::6ab3). The obligations regarding taxation and reporting of crypto assets are distinct from the obligations regarding AML/CFT supervision and cooperation with authorities. There is no specific obligation in one regime that pushes against a specific obligation in the other; rather, they regulate different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:8e5eb5b8877691fbba38a5b0", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU AML/CTF Act + Rules"}, "regime_b": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU Travel Rule (IFTI)"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "254ca2d92d196180::369::b111", "source_doc": "Anti-Money Laundering act 2006.pdf", "page": 98, "passage": "Part 2 Identification procedures etc. Division 2 Identification procedures for certain pre-commencement customers\nSection 29\n(b) after the commencement of this section, a suspicious matter\nreporting obligation arises for the reporting entity in relation\nto the customer. Note 1: For suspicious matter reporting obligation, see section 41. Note 2: For tipping-off offences, see section 123. Requirement\n(2) The reporting entity must:\n(a) take such action as is specified in the AML/CTF Rules; and\n(b) do so within the time limit allowed under the AML/CTF\nRules. Civil penalty\n(3) Subsection (2) is a civil penalty provision. Interpretation\n(4) For the purposes of this section, assume that Part 1 had been in\nforce at all material times before the commencement of this\nsection.\n80 Anti-Money Laundering and Counter-Terrorism Financing Act 2006 Identification procedures etc."}, {"chunk_id": "254ca2d92d196180::43c::0a91", "source_doc": "Anti-Money Laundering act 2006.pdf", "page": 98, "passage": "Part 2\nIdentification procedures for certain low-risk services Division 3\nSection 30\nDivision 3-Identification procedures for certain low-risk\nservices\n30 Identification procedures for certain low-risk services\nScope\n(1) This section applies to the provision by a reporting entity of a\ndesignated service to a customer if, under the AML/CTF Rules, the\nservice is taken to be a low-risk designated service. (2) Sections 32 and 34 do not apply to the provision by the reporting\nentity of the designated service to the customer. Note: For special rules about verification of identity etc., see section 31.\n31 Verification of identity of low-risk service customer etc. Scope\n(1) This section applies to a reporting entity if:\n(a) at a particular time (the relevant time), the reporting entity\ncommences to provide a designated service to a customer;\nand\n(b) under the AML/CTF Rules, the service is taken to be a\nlow-risk designated service; and\n(c) at the relevant time or a later time, a suspicious matter\nreporting obligation arises for the reporting entity in relation\nto the customer."}], "evidence_b": [{"chunk_id": "561fc09c315f8349::45d::68bb", "source_doc": "Money transferred to and from overseas International funds transfer instruction (IFTI) reports.pdf", "page": null, "passage": "In\nan IFTI-E: e the transfer instruction is carried out or passed on electronically https://www.austrac.gov.au/business/core-guidance/reporting/money-transferred-and-overseas-international-funds-transfer-instruction-ifti-reports 2/6 25/06/2025, 23:15 Money transferred to and from overseas: International funds transfer instruction (IFTI) reports | AUSTRAC e the transfer is within the same financial institution or between financial\ninstitutions, such as banks, building societies or credit unions. An IFTI-E can be either:\ne outgoing - the ordering institution accepts the instruction in Australia and transfers money to the payee via a beneficiary institution overseas e incoming - the ordering institution accepts the instruction overseas and\ntransfers money via a beneficiary institution in Australia. Information required in IFTI-E reports\nIFTI-E reports must include details about everyone involved in the transfer:\ne the payer - the business, organisation or individual who instructs the ordering\ninstitution to transfer money\ne the ordering institution - the institution that accepts the transfer instruction"}, {"chunk_id": "561fc09c315f8349::462::56cd", "source_doc": "Money transferred to and from overseas International funds transfer instruction (IFTI) reports.pdf", "page": null, "passage": "e the sender (if the sender is not the ordering institution) - the financial\ninstitution that transmits the instruction to the beneficiary institution. This is\noften the ordering institution, but not always. e the beneficiary institution - the financial institution that receives the instruction\nand makes the money available to the payee e the payee - the business, organisation or individual who ultimately receives\nthe transferred money e any intermediary institutions - other institutions in the transfer chain between\nthe sender and the beneficiary institution. You may also have to report details such as: e transaction dates e the amount and type of currency e the identification code assigned to the instruction e any information or directions the payer gave to the payee e any information or directions one of the institutions gives another https://www.austrac.gov.au/business/core-guidance/reporting/money-transferred-and-overseas-international-funds-transfer-instruction-ifti-reports 3/6 25/06/2025, 23:15 Money transferred to and from overseas: International funds transfer instruction (IFTI) reports | AUSTRAC"}], "rationale": "AU_TRAVEL_RULE is the AUSTRAC IFTI / EFTI guidance — a narrowed view of the AML/CTF Act + Rules covering wire-transfer-information obligations. AU_FEDREG_AML is the binding statutory and regulatory instrument set. The two are the same regime viewed at different granularities: the travel-rule guidance implements specific provisions of the Act and Rules. No obligation collision possible.", "would_conflict_if": ["AUSTRAC guidance materially diverged from the binding Act/Rules — operational risk, not regime conflict."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:25:58Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:20c9e4210e6d2484e80fb423", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}], "rationale": "The regimes regulate distinct domains. Regime A (AU_APRA_CPS234) is a Prudential Practice Guide focused on operational risk management and information security for APRA-regulated entities (chunk 4b6fab404e7acfca::3c4::1564). Regime B (EU_MAR) is a European Union regulation establishing a framework to prevent market abuse, insider dealing, and market manipulation to ensure market integrity (chunk 5cc4a27bc578287a::165::3333). There is no evidence in the provided passages of a specific obligation in one regime conflicting with a specific obligation in the other; they address separate compliance areas."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:15:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:c857ac9766ee9be926c8977f", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::41f::546c", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 24, "passage": "3.1 Standard AFSL Obligations\nAustralian financial services licence\n(a) A platform provider must hold an AFSL authorising them to issue and deal in digital asset facilities.\n(b) A platform provider is exempt from holding an AFSL for digital asset facilities if:\n(i) the total value of platform entitlements held by any one client of the platform provider does\nnot exceed $1,500 at any one time; and\n(ii) the total amount of assets held by the platform provider does not exceed $5 million at any\ntime.\nInfo Box 3 Low value exemption\nThe risks with digital asset facilities are correlated to the size and scale of the asset holding role of\nthe platform provider. Accordingly, a 'low-value facility' exemption would be introduced, similar to\nthe 'low value facility' exemption for non-cash payment facilities. It would apply to digital asset\nfacilities holding less than $1,500 per customer and less than $5 million in total.40 This exemption\nis intended to allow for innovation and experimentation in the early stages of developing a novel\nservice offering."}, {"chunk_id": "550958b067dc6726::709::b159", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 15, "passage": "2.3 Overview of proposed framework\nLicensing\nThe proposed framework would recognise certain asset holding arrangements as a financial product (a\ndigital asset facility). The existing AFSL framework would apply to any person 'carrying on a financial\nservices business in Australia' in relation to a digital asset facility. Examples of 'financial services'\ninclude:\n• dealing in a financial product (including applying for or acquiring, issuing, varying or disposing of a\nfinancial product)\n• making a market for a financial product\n• providing a custodial or depository service, and\n• providing financial product advice.\nThe issuer of a digital asset facility would be the person or persons responsible for the obligations\nowed to customers under the terms of the asset holding arrangement (platform provider). Platform\nproviders and other intermediaries performing financial services in relation to digital asset facilities\n(e.g. brokers, arrangers, agents, market makers, and advisers) would be required to hold an AFSL.\nWhile the application of the AFSL regime would be jurisdictionally limited to Australia in the usual way,\nan intermediary business in Australia, like a broker, would need to be licensed to provide services that\ninvolve dealing in digital asset facilities generally (including those not licensed or located in Australia).\nSee Part 3 for further detail about licensing obligations.\nFacility contracts\nThe proposed framework would permit digital asset facilities to be paired with other functions,\ncreating digital asset platforms. All arrangements involving digital asset facilities would be required to\nbe structured as non-discretionary arrangements.29 The term 'non-discretionary' means the\narrangements must operate according to pre-agreed and transparent rules and procedures."}], "evidence_b": [{"chunk_id": "3d9b3d4849297e91::3c6::7b85", "source_doc": "2025_CP_Prudential_Treatment_Cryptoassets.pdf", "page": null, "passage": "Preface | 4\n1.6 MAS invites comments from banks and other interested parties. Please refer to Annex A for the list of\nquestions.\n1.7 Please note that all submissions received will be published and attributed to the respective respondent\nunless they expressly request MAS not to do so. As such, if respondents would like\n(a) their whole submission or part of it (but not their identity), or\n(b) their identity along with their whole submission,\nto be kept confidential, please expressly state so in the submission to MAS. MAS will only publish\nnon-anonymous submissions. In addition, MAS reserves the right not to publish any submission\nreceived where MAS considers it not in the public interest to do so, such as where the submission\nappears to be libelous or offensive.\n1.8 Please submit written comments via email to prudential_policy_dept@mas.gov.sg using the suggested\ntemplate by 28 April 2025. Prudential Treatment & Disclosures of Cryptoasset Exposures | 5\n2."}, {"chunk_id": "7c04f2a0bd85290a::46d::fd1b", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "Binance is supportive of the redemption-related requirements. In general, five business\ndays should be sufficient to return the par value of the SCS to customers. However, given\nthat this is ultimately dependent on the availability of the relevant banking services,\nBinance would propose that this is aligned to the prevailing turnaround time provided by\nthe financial institution that the reserve assets are held with. Question 7. MAS seeks comments on whether the prudential requirements outlined in paragraph\n4.21 are risk proportionate. MAS welcomes suggestions on alternative approaches to\naddress the risks. Binance is supportive of the prudential requirements outlined in paragraph 4.21. 15 August 2023 | 23\nQuestion 10. MAS seeks comments on whether the scenario outlined in paragraph 4.22 is a likely\ndevelopment and whether the approaches outlined in paragraph 4.24 are feasible. MAS\nwelcomes suggestions on other approaches to address this issue. As per Q1, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction."}], "rationale": "The evidence for AU_ASIC_AFSL focuses on the requirement for a platform provider to hold an Australian Financial Services Licence (AFSL) to issue and deal in digital asset facilities, and the financial requirements associated with that licence (e.g., solvency, NTA). The evidence for SG_MAS_PRUDENTIAL_CRYPTO discusses the Monetary Authority of Singapore's invitation for comments on prudential treatment and disclosures of cryptoasset exposures, and the general principle of imposing higher financial and prudential standards on stablecoin issuers. The obligations in the Australian regime (holding an AFSL and meeting financial requirements) are distinct from the Singaporean regime's focus on prudential treatment and capital frameworks for cryptoasset exposures. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other; rather, they regulate different aspects of the digital asset ecosystem (licensing and financial requirements vs. prudential treatment and disclosures)."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:19:21Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:92301fee44135be2c6e86fa0", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The EU_MICA_RTS passage (chunk_id=c51ad46265cea4e5::2f5::4513) discusses the notification obligations of financial entities providing crypto-asset services under MiCA. The INT_IOSCO_GENERAL passage (chunk_id=f173909614befd49::455::1a1a) outlines the general objectives and principles of securities regulation, noting that IOSCO Principles are key standards highlighted by the FSB. The obligations in MiCA regarding crypto-asset service providers are specific to the EU regulatory framework, whereas the IOSCO passage provides high-level international principles and methodology. There is no specific obligation in the IOSCO passage that creates a conflict with the notification obligations in MiCA; they regulate different domains (EU crypto-asset regulation vs. general international securities regulation)."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:bb36e71d361c4a558814385f", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 230"}, "regime_b": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "ASIC crypto-asset guidance"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): APRA CPS 230 operational-risk management standard and ASIC's crypto-asset INFO 225 / RG 282 guidance operate in disjoint regulatory domains at the obligation level. Prudential operational-risk standard vs market-conduct crypto-asset guidance — disjoint obligation surfaces. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:04:21Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:02d62cfd86dd3df21e733c97", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}], "rationale": "The AU_TRAVEL_RULE passages discuss Australia's regulatory framework for digital currency exchanges and the implementation of FATF's 'Travel Rule' for identifying parties in transactions. The EU_PSD2 passages regulate payment service providers, focusing on strong customer authentication (SCA) and security measures for payment accounts and transactions. The obligations are distinct: one addresses the identification of parties in cross-border value transfers (Travel Rule), while the other addresses the authentication of payment transactions to prevent fraud. There is no specific obligation in PSD2 that conflicts with the implementation of the Travel Rule in Australia."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:29:11Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:e9b54debc61e96a4c88684e0", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "rationale": "The Australian Taxation Office (ATO) regime focuses on tax compliance, consumer protection, and the mapping of crypto assets for regulatory purposes (chunk_id e6bb47e92e88e16c::567::36c4). In contrast, the Basel regime addresses prudential capital requirements for internationally active banks (chunk_id 32afd37cade34f84::3a4::1a5b). The obligations in the ATO passage relate to tax reporting and consumer interest, while the Basel passage relates to bank capital adequacy and supervision. These are distinct regulatory domains that do not impose conflicting obligations on the same entity or transaction type."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:04:12Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:a694f998a96ec020a662e538", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4024f4c4c1616cc::23d::700a", "source_doc": "AMLR_Regulation_EU_2024-1624.pdf", "page": 2, "passage": "(7) Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers\nof funds and certain crypto-assets and amending Directive (EU) 2015/849 (OJ L 150, 9.6.2023, p. 1).\n\n(8) Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing the Authority for\nAnti-Money Laundering and Countering the Financing of Terrorism and amending Regulations (EU) No 1093/2010, (EU)\nNo 1094/2010 and (EU) No 1095/2010 (OJ L, 2024/1620, 19.6.2024, http://data.europa.eu/eli/reg/2024/1620/oj)."}, {"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The EU AMLR TFR passages (c4024f4c4c1616cc::23d::700a, c0300673081f7232::279::1918) establish obligations for crypto-asset service providers regarding information accompanying transfers of funds and anti-money laundering (AML) compliance. The MAS TRM passages (20d526d712753652::401::f956) discuss the application of principles-based guidelines (TRM Guidelines) to licensees, focusing on risk assessments and industry best practices. The obligations in the EU regime relate to the technical traceability of crypto-asset transfers for AML purposes, while the MAS regime focuses on the governance and risk management standards for licensees. These are distinct regulatory domains; the EU rules do not impose specific operational requirements on MAS licensees that would conflict with the MAS TRM Guidelines, nor do the MAS guidelines impose specific technical reporting requirements that would conflict with the EU AML obligations. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:dba04a3376b416c245eef3e7", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}, {"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "AU_ASIC_CRYPTO (crypto financial-product classification) and SG_FSMA_DTSP (Singapore's DTSP licensing under the FSM Act) both address crypto-asset service licensing in their respective jurisdictions but apply different licensing perimeters and entity definitions. No specific obligation in one pushes against a specific obligation in the other on the cited evidence."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:01:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:b5d3df5dfe4c019402c8646d", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The EU_MIFID2 passages regulate the conduct of investment firms, focusing on product governance, suitability assessments, and client information disclosure (e.g., Article 1 and Article 25). In contrast, the INT_BASEL_CRYPTO passages regulate the prudential capital requirements and risk-weighting of bank exposures to financial institutions (e.g., definitions of bank exposures and treatment of securities firms). The obligations in MIFID2 regarding client suitability and product approval do not impose conflicting requirements on the capital adequacy or risk-weighting calculations governed by Basel. Therefore, the regimes operate in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:50:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:baa65c4584ecf56fe0c26e8e", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}, {"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The INT_BASEL_CRYPTO passages discuss capital requirements, risk weighting, and prudential standards for banks and financial institutions (e.g., Basel III capital buffers, netting arrangements, and treatment of exposures to securities firms). The MAS_TRM passages discuss the application of guidelines to licensees, including the TRM Guidelines and F&P Guidelines, and feedback on their implementation. The obligations in Regime A relate to financial institution capital and risk management, while the obligations in Regime B relate to licensing, governance, and compliance with MAS guidelines. These are distinct regulatory domains; there is no specific obligation in Regime A that pushes against a specific obligation in Regime B. Therefore, the regimes do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:01:12Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:1e83b28225476b4a5f543b3a", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c4a92930a8caf822::380::0a18", "source_doc": "AML_CTF_Rules_2025.pdf", "page": 12, "passage": "Part 1 Preliminary\nSection 1-4\n(a) in relation to registration or proposed registration of a person under Part 6\nof the Act as a remittance network provider-registrable remittance\nnetwork services; or\n(b) in relation to registration or proposed registration of a person under Part 6\nof the Act as an independent remittance dealer or a remittance affiliate of a\nregistered remittance network provider-registrable remittance services; or\n(c) in relation to registration or proposed registration of a person under Part 6A\nof the Act as a virtual asset service provider-registrable virtual asset\nservices.\nrelated body corporate has the same meaning as in the Corporations Act 2001.\nsuper-agent has the meaning given by subsection 4-13(2).\ntracing information, in relation to a transfer of value, means information that\nsatisfies both of the following:\n(a) the information:\n(i) for a transfer from an"}, {"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}], "evidence_b": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}], "rationale": "The AU_TRAVEL_RULE passages discuss the Australian regulatory framework for remittance networks, virtual asset service providers, and the FATF 'Travel Rule' for digital currency exchanges (chunk_ids c4a92930a8caf822::380::0a18, cf7cefacba3f94bc::383::7d9d). In contrast, the EU_MAR passages focus exclusively on the regulation of market abuse, insider dealing, and market manipulation in financial markets (chunk_id 5cc4a27bc578287a::165::3333). The obligations regarding financial market integrity and transaction reporting under EU_MAR do not overlap with the obligations regarding remittance networks and virtual asset services under AU_TRAVEL_RULE. Therefore, the regimes are in different domains."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:21:27Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:5a6ff41b82bbeebe587f4d8a", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "a7dacedbb913f57b::593::ebeb", "source_doc": "FinalReport_MiCA_CP2.pdf", "page": null, "passage": "8.5 Annex V: Draft RTS pursuant to Article 68(10)(a) of MiCA ............................... 197 8.6 Annex VI: Draft RTS pursuant to Article 76(16)(a) of MiCA .............................. 206\n8.7 Annex VII: Draft RTS pursuant to Article 68(10)(b) of MiCA ............................. 226\n8.8 Annex VIII: Draft RTS pursuant to Article 76(16)(b) of MiCA ............................ 276\n8.9 Annex IX: Draft ITS pursuant to Articles 6, 19 & 51 of MiCA ............................. 311\n8.10 Annex X: Draft RTS pursuant to Article 109(8) of MiCA .................................... 401\n8.11 Annex XI: Draft ITS pursuant to Article 88(4) of MiCA ...................................... 413 List of acronyms\nART Asset-referenced token\nBCP Business continuity policy\nCASP Crypto-asset service provider\nCSRD Directive (EU) 2022/2464 of the European Parliament and of the Council of 14\nDecember 2022 amending Regulation (EU) No 537/2014, Directive\n2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU, as regards\ncorporate sustainability reporting (Corporate Sustainability Reporting Directive)\nDLT Distributed ledger technology\nDORA Regulation (EU) 2022/2554 of the European Parliament and of the Council of\n14 December 2022 on digital operational resilience for the financial sector\n(Digital Operational Resilience Act) and amending Regulations (EC) No\n1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU) No 909/2014 and (EU)"}], "rationale": "The evidence for the Australian regime (AU_ATO_CRYPTO) focuses on token mapping, tax compliance, and general crypto ecosystem regulation (chunk_id e6bb47e92e88e16c::567::36c4). The evidence for the European regime (EU_MICA_RTS) outlines the structure of MiCA, including the development of RTS and ITS, and lists acronyms such as CASP and ART (chunk_id a7dacedbb913f57b::593::ebeb). The passages describe the regulatory frameworks and their respective objectives rather than specific operational obligations that would create a conflict. Therefore, the regimes regulate different domains and do not impose conflicting obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-05-26T01:13:52Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.8, "record_type": "conflict", "pair_id": "conflict:43d49ff5c532878c3d62a04f", "label": "conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title IV (EMT)"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG MAS Stablecoin"}, "conflict_type": "structural_unresolved", "severity": "high", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::321::0923", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 74, "passage": "Article 57\nVoluntary classification of e-money tokens as significant e-money tokens\n1.\nAn issuer of an e-money token, authorised as a credit institution or as an electronic money institution, or applying\nfor such authorisation, may indicate that it wishes for its e-money token to be classified as a significant e-money token.\nIn that case, the competent authority shall immediately notify such request of the issuer to EBA, to the ECB and, in the\ncases referred to in Article 56(3), second subparagraph, to the central bank of the Member State concerned.\nIn order for the e-money token to be classified as significant under this Article, the issuer of the e-money token shall\ndemonstrate, through a detailed programme of operations, that it is likely to meet at least three of the criteria set out in"}, {"chunk_id": "491a2f0014d56ffb::3f8::b0ef", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 68, "passage": "Article 49\nIssuance and redeemability of e-money tokens\n1.\nBy way of derogation from Article 11 of Directive 2009/110/EC, in respect of the issuance and redeemability of e-\nmoney tokens only the requirements set out in this Article shall apply to issuers of e-money tokens.\n2.\nHolders of e-money tokens shall have a claim against the issuers of those e-money tokens.\n3.\nIssuers of e-money tokens shall issue e-money tokens at par value and on the receipt of funds.\nEN\nL 150/107\n\n4.\nUpon request by a holder of an e-money token, the issuer of that e-money token shall redeem it, at any time and\nat par value, by paying in funds, other than electronic money, the monetary value of the e-money token held to the\nholder of the e-money token.\n5.\nIssuers of e-money tokens shall prominently state the conditions for redemption in the crypto-asset white paper as\nreferred to in Article 51(1), first subparagraph, point (d).\n6.\nWithout prejudice to Article 46, the redemption of e-money tokens shall not be subject to a fee."}, {"chunk_id": "491a2f0014d56ffb::53d::70f2", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 13, "passage": "(66)\nIssuers of e-money tokens should be authorised either as a credit institution under Directive 2013/36/EU or as an\nelectronic money institution under Directive 2009/110/EC. E-money tokens should be deemed to be 'electronic\nmoney' as that term is defined in Directive 2009/110/EC and their issuers should, unless specified otherwise in\nthis Regulation, comply with the relevant requirements set out in Directive 2009/110/EC for the taking up,\npursuit and prudential supervision of the business of electronic money institutions and the requirements on\nissuance and redeemability of e-money tokens. Issuers of e-money tokens should draw up a crypto-asset white\npaper and notify it to their competent authority. Exemptions regarding limited networks, regarding certain\ntransactions by providers of electronic communications networks and regarding electronic money institutions\nissuing only a limited maximum amount of electronic money, based on the optional exemptions specified in\nDirective 2009/110/EC, should also apply to e-money tokens. However, issuers of e-money tokens should still be\nrequired to draw up a crypto-asset white paper in order to inform buyers about the characteristics and risks of\nthe e-money tokens and should also be required to notify the crypto-asset white paper to the competent authority\nbefore its publication."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::34c::8d20", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 19, "passage": "15 August 2023 | 19\nAnnex A: Summary of Finalised Key\nRequirements\nKEY REQUIREMENTS FOR MAS-REGULATED STABLECOIN ISSUERS\nRequirements for MAS-regulated stablecoin issuers\n• Denominated in currency of stablecoin peg\n• Held in cash/ cash equivalents/ debt securities with up to three-\nmonth residual maturity and issued by (i) government or central bank\nComposition\nof pegged currency; or (ii) organisations that are of both a\ngovernmental and international character with a minimum credit\nrating of \"AA-\"\n• At least equivalent to par value of SCS in circulation at all times\nValuation\n• Valued at mark-to-market basis daily\nRESERVE • Held in segregated accounts on trust\nASSETS • Held in permitted custodians as follows:\n- Financial institutions licensed for custodial services in Singapore\nSegregation &\nby MAS; or\nCustody\n- Overseas-based cust"}, {"chunk_id": "7c04f2a0bd85290a::40b::3ddb", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 37, "passage": "15 August 2023 | 46\nWe believe that the proposed changes are sufficient. Under the current Payment Services\nAct 2019 (\"PS Act\") framework, stablecoins are treated as DPTs. In accordance with the\ncurrent scope of the PS Act, entities that deal in and/or facilitate the exchange of\nstablecoins therefore fall within the scope of regulated DPT services. However, stablecoin issuers are presently not regulated in terms of ensuring the value\nstability of stablecoins. Accordingly, the \"Stablecoin Issuance Service\" will regulate entities\nbased in Singapore that perform the function of controlling the total supply, minting and\nburning of a SCS. Such an SCS will be labelled using a specific term, such as \"regulated\nstablecoin\", \"qualifying stablecoin\" or \"securely-backed stablecoin\". This is well balanced\nwith the PS Act as activities relating to other types of stablecoins, including algorithmic,\ncommodity-backed, multi-currency and other types of stablecoins, will continue to be\nsubject to the existing DPT regime under the PS Act."}, {"chunk_id": "7c04f2a0bd85290a::429::7290", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "Specifically, we would like to seek clarity on the application of provisions in the PS Act\nrelating to licensing of payment service providers, and the prohibition against solicitation. 15 August 2023 | 92\n(a) Will section 5 of the PS Act prohibit Overseas Issuers from carrying on a business of\nproviding regulated SCS issuance services in Singapore? Or will Overseas Issuers be\nprohibited from carrying on a business of providing any stablecoin issuance services in\nSingapore? (b) Will section 9 of the PS Act prohibit Overseas Issuers from offering to provide\nregulated SCS issuance services in Singapore? Or will Overseas Issuers be prohibited from\noffering to provide any stablecoin issuance services in Singapore? Question 2. MAS seeks comments on whether it is sufficient to introduce an additional regulated\npayment service of stablecoin issuance, and whether there is a need to introduce any\nother regulated services specific to stablecoins. We are supportive of the intention to introduce an additional regulated payment service\nof SCS/stablecoin issuance."}], "rationale": "EU MiCA Title IV requires an Electronic Money Token to be issued by an EU-established credit institution or electronic money institution, with reserve, redemption-at-par and ongoing prudential obligations. The MAS Single-Currency Stablecoin framework imposes a parallel set of obligations — reserve composition, redemption, disclosure — but only for stablecoins pegged to SGD or a G10 currency *and* issued by a MAS-licensed issuer based in Singapore. The two regimes share the same economic goal (a robust fiat-pegged stablecoin) but each ties authorisation to a specific national legal entity. There is no transit: an EU-authorised EMT cannot be marketed in Singapore as an SCS without a separate MAS licence, and an SG SCS cannot enter the EU as a MiCA EMT without a separate EU issuer. For an AU-issued AUDD (which sits outside both perimeters), the practical effect is the same — neither regime extends a recognition pathway, and the issuer must structurally duplicate to operate in both markets. The conflict is structural rather than operationally resolvable because the gating element in each regime is the *identity and jurisdiction of the issuer*, not the design or behaviour of the token; no operational layer (SCCs, contracts, disclosures) can substitute for the issuer-licence requirement.", "compliant_paths": ["Establish a separately-licensed issuer in each target jurisdiction (EU EMI + SG MAS-licensed SCS issuer).", "Restrict the product's marketing and availability to one jurisdiction's residents and rely on territoriality."], "out_of_scope_assumptions": ["The SCS framework is treated as it stood in MAS's 2023 final response; future MAS amendments could (in principle) recognise EU EMTs.", "MiCA's reverse-solicitation gateway (Art. 61) does not provide a structural alternative — it covers narrow client-initiated cases, not issuer authorisation."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:14497d4771ed6587fbf1a194", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::25d::6825", "source_doc": "d424.pdf", "page": 85, "passage": "150. At national supervisory discretion, banks using both the standardised and IRB approaches may\nrely on their internal methods for allocating general provisions for recognition in capital under either the\nstandardised or IRB approach, subject to the following conditions. Where the internal allocation method\nBasel III: Finalising post-crisis reforms 81\n\nis made available, the national supervisor will establish the standards surrounding their use. Banks will\nneed to obtain prior approval from their supervisors to use an internal allocation method for this purpose.\n\n3. Treatment of EL and provisions"}], "rationale": "The EU_PSD2 passages regulate payment service authentication, security credentials, and authorisation requirements for payment institutions (e.g., Article 97, Article 4 definitions). The INT_BASEL_GENERAL passages regulate banking capital adequacy, leverage ratios, and the treatment of provisions and expected losses (e.g., paragraph 11 on fiduciary assets, paragraph 150 on general provisions). The obligations in the EU_PSD2 text do not impose requirements that conflict with the capital and accounting obligations described in the INT_BASEL_GENERAL text. The regimes govern distinct aspects of financial regulation—payment services versus banking capital—resulting in no overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:09:48Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:accfdfc8ceb01b9ff05e84de", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e3809bb1f352508e::38a::ddd7", "source_doc": "Guidelines_Reverse_Solicitation_MiCA.pdf", "page": 14, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}, {"chunk_id": "25cbbd878a1b21d3::38a::ddd7", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 47, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}], "rationale": "The EU_MICA passages describe specific obligations regarding crypto-asset service provision, market abuse prevention, and licensing requirements (e.g., Article 92(1) and Article 81(15)(a)). The INT_FATF_GENERAL passages provide high-level guidance on general principles for assessing money laundering and terrorist financing (ML/TF) risks at the national level and do not contain specific obligations applicable to crypto-asset service providers or market abuse. The regimes regulate distinct domains: MiCA establishes a detailed regulatory framework for crypto-assets, while FATF provides international standards for AML/CFT. There is no specific obligation in MiCA that pushes against a specific obligation in FATF in the provided text."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:46:10Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:7f153a65a59ccd21e5f5a0da", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DORA"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::3d7::f935", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 15, "passage": "(68) To evaluate and monitor on a regular basis the ability of an ICT third party service provider to securely provide\nservices to a financial entity without adverse effects on a financial entity's digital operational resilience, several key\ncontractual elements with ICT third-party service providers should be harmonised. Such harmonisation should\ncover minimum areas which are crucial for enabling a full monitoring by the financial entity of the risks that could\nemerge from the ICT third-party service provider, from the perspective of a financial entity's need to secure its\ndigital resilience because it is deeply dependent on the stability, functionality, availability and security of the ICT\nservices received.\n\n(69) When renegotiating contractual arrangements to seek alignment with the requirements of this Regulation, financial\nentities and ICT third-party service providers should ensure the coverage of the key contractual provisions as\nprovided for in this Regulation."}, {"chunk_id": "85307f9e2a040982::5f2::974e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 23, "passage": "Article 1\nSubject matter\n1. In order to achieve a high common level of digital operational resilience, this Regulation lays down uniform\nrequirements concerning the security of network and information systems supporting the business processes of financial\nentities as follows:\n(a) requirements applicable to financial entities in relation to:\n(i) information and communication technology (ICT) risk management;\n(ii) reporting of major ICT-related incidents and notifying, on a voluntary basis, significant cyber threats to the\ncompetent authorities;\n(iii) reporting of major operational or security payment-related incidents to the competent authorities by financial\nentities referred to in Article 2(1), points (a) to (d);\n(iv) digital operational resilience testing;\n(v) information and intelligence sharing in relation to cyber threats and vulnerabilities;\n(vi) measures for the sound management of ICT third-party risk;\n(b) requirements in relation to the contractual arrangements concluded between ICT third-party service providers and\nfinancial entities;\n(c) rules for the establishment and conduct of the Oversight Framework for critical ICT third-party service providers when\nproviding services to financial entities;\n(d) rules on cooperation among competent authorities, and rules on supervision and enforcement by competent\nauthorities in relation to all matters covered by this Regulation.\n2. In relation to financial entities identified as essential or important entities pursuant to national rules transposing"}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The obligations in EU_DORA focus on digital operational resilience, ICT risk management, and contractual arrangements with ICT third-party service providers (chunk_ids 85307f9e2a040982::3d7::f935, 85307f9e2a040982::5f2::974e). In contrast, the obligations in INT_BASEL_CRYPTO address capital requirements, risk-weighting of bank exposures, and prudential standards for financial institutions (chunk_ids 32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). The regimes regulate distinct aspects of financial stability—digital resilience versus capital adequacy—and do not impose conflicting obligations on the same activity."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.7, "record_type": "conflict", "pair_id": "conflict:cedeb857bc3231812ada35e9", "label": "conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "conflict_type": "interpretive_fact_sensitive", "severity": "low", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}], "rationale": "INT_FATF_VASP (FATF VASP definition and AML obligations) and AU_ATO_CRYPTO (ATO crypto-asset tax framework). Whether a particular AU crypto-asset operator falls within the FATF VASP definition (vs a non-VASP financial intermediary) turns on FACTS about the services provided — distinct downstream AML obligations. Low severity because the AU tax framework applies regardless of the VASP classification.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:21Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "low", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:7935be19c52dd24ec6638832", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + TFR"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title V (CASP)"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::452::8eaf", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 63; or\n(b) a credit institution, central securities depository, investment firm, market operator, electronic money institution,\nUCITS management company, or an alternative investment fund manager that is allowed to provide crypto-asset\nservices pursuant to Article 60. EN\nL 150/114 2. Crypto-asset service providers authorised in accordance with Article 63 shall have a registered office in a Member\nState where they carry out at least part of their crypto-asset services. They shall have their place of effective management\nin the Union and at least one of the directors shall be resident in the Union.\n3. For the purposes of paragraph 1, point (a), other undertakings that are not legal persons shall only provide crypto-\nasset services if their legal form ensures a level of protection for third parties' interests equivalent to that afforded by\nlegal persons and if they are subject to equivalent prudential supervision appropriate to their legal form.\n4. Crypto-asset service providers authorised in accordance with Article 63 shall at all times meet the conditions for\ntheir authorisation.\n5."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLR/TFR AML/CFT + travel-rule and EU MiCA Title V crypto-asset service provider regime are designed to coexist — obligations apply cumulatively without collision. CASPs under MiCA Title V are explicitly covered by AMLR and the TFR travel-rule regime — aligned. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:50:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.72, "record_type": "conflict", "pair_id": "conflict:17ad04da3ea8d5a7bc9578ab", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "GDPR"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "PSD2"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::4a6::7573", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 1, "passage": "Consistent and\nhomogenous application of the rules for the protection of the fundamental rights and freedoms of natural\npersons with regard to the processing of personal data should be ensured throughout the Union. Regarding the\nprocessing of personal data for compliance with a legal obligation, for the performance of a task carried out in\nthe public interest or in the exercise of official authority vested in the controller, Member States should be\nallowed to maintain or introduce national provisions to further specify the application of the rules of this\nRegulation. In conjunction with the general and horizontal law on data protection implementing Directive\n95/46/EC, Member States have several sector-specific laws in areas that need more specific provisions. This\nRegulation also provides a margin of manoeuvre for Member States to specify its rules, including for the\nprocessing of special categories of personal data ('sensitive data'). To that extent, this Regulation does not exclude\nMember State law that sets out the circumstances for specific processing situations, including determining more\nprecisely the conditions under which the processing of personal data is lawful."}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "bd84e63f5b622b73::5e9::a119", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 48, "passage": "Article 25\nData protection by design and by default\n1. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of\nprocessing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the\nprocessing, the controller shall, both at the time of the determination of the means for processing and at the time of the\nprocessing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are\ndesigned to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the\nnecessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of\ndata subjects.\n2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default,\nonly personal data which are necessary for each specific purpose of the processing are processed. That obligation applies\nto the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility.\nIn particular, such measures shall ensure that by default personal data are not made accessible without the individual's\nintervention to an indefinite number of natural persons.\n3. An approved certification mechanism pursuant to Article 42 may be used as an element to demonstrate\ncompliance with the requirements set out in paragraphs 1 and 2 of this Article."}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::5e8::48cc", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 59, "passage": "Article 67\nRules on access to and use of payment account information in the case of account information services\n1. Member States shall ensure that a payment service user has the right to make use of services enabling access to\naccount information as referred to in point (8) of Annex I. That right shall not apply where the payment account is not\naccessible online.\n2. The account information service provider shall:\n(a) provide services only where based on the payment service user's explicit consent;\n(b) ensure that the personalised security credentials of the payment service user are not, with the exception of the user\nand the issuer of the personalised security credentials, accessible to other parties and that when they are transmitted\nby the account information service provider, this is done through safe and efficient channels;\n(c) for each communication session, identify itself towards the account servicing payment service provider(s) of the\npayment service user and securely communicate with the account servicing payment service provider(s) and the\npayment service user, in accordance with point (d) of Article 98(1);\n(d) access only the information from designated payment accounts and associated payment transactions;\n(e) not request sensitive payment data linked to the payment accounts;\n(f) not use, access or store any data for purposes other than for performing the account information service explicitly\nrequested by the payment service user, in accordance with data protection rules.\n3."}, {"chunk_id": "adb1a81b9cecaf8c::2b6::9daa", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 58, "passage": "Article 66\nRules on access to payment account in the case of payment initiation services\n1. Member States shall ensure that a payer has the right to make use of a payment initiation service provider to obtain\npayment services as referred to in point (7) of Annex I. The right to make use of a payment initiation service provider\nshall not apply where the payment account is not accessible online.\n2. When the payer gives its explicit consent for a payment to be executed in accordance with Article 64, the account\nservicing payment service provider shall perform the actions specified in paragraph 4 of this Article in order to ensure the\npayer's right to use the payment initiation service.\n3."}, {"chunk_id": "adb1a81b9cecaf8c::43b::29d2", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 6, "passage": "(30) The personalised security credentials used for secure customer authentication by the payment service user or by the\npayment initiation service provider are usually those issued by the account servicing payment service providers.\nPayment initiation service providers do not necessarily enter into a contractual relationship with the account\nservicing payment service providers and, regardless of the business model used by the payment initiation service\nproviders, the account servicing payment service providers should make it possible for payment initiation service\nproviders to rely on the authentication procedures provided by the account servicing payments service providers to\ninitiate a specific payment on behalf of the payer.\n\n(31) When exclusively providing payment initiation services, the payment initiation service provider does not at any\nstage of the payment chain hold the user's funds. When a payment initiation service provider intends to provide\npayment services in relation to which it holds user funds, it should obtain full authorisation for those services."}], "rationale": "PSD2's open-banking architecture (Articles 66-67 on payment initiation services and account information services, Article 97 on strong customer authentication) requires mandatory third-party access to payment-account personal data on the customer's instruction. GDPR Articles 5-7 demand minimisation, purpose limitation and explicit lawful basis. PSD2 Recital 30 explicitly references data protection law as applicable. The tension is real: PSD2 pushes for mandated disclosure of personal payment data to AISPs/PISPs, while GDPR demands controllable scope. EDPB Guidelines 06/2020 on the interplay of PSD2 and GDPR resolve the tension by requiring AISP/PISP access on the basis of GDPR Art. 6(1)(b) (contract) — the customer's own request creates the lawful basis. Practitioners must design consent flows that distinguish the PSD2 'explicit consent' (Art 94(2)) from the GDPR 'consent' lawful basis (Art 6(1)(a)).", "compliant_paths": ["AIS/PIS access by AISPs/PISPs operates on GDPR Art 6(1)(b) (contract performance triggered by customer request), not Art 6(1)(a) (consent).", "Document PSD2 Art 94(2) 'explicit consent' as a sector-specific procedural requirement, not as the GDPR lawful basis.", "Build dynamic consent flows that allow per-account, per-AISP-PISP scope control per EDPB Guidelines 06/2020."], "out_of_scope_assumptions": ["PSP and AISP/PISP are EU-authorised; third-country open-banking arrangements have a different Chapter V transfer analysis."]}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.86, "record_type": "non_conflict", "pair_id": "non_conflict:a186b441e7bd25cdc330d5ba", "label": "non_conflict", "regime_a": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "MAS TRM Guidelines"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "PDPA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "2b8959e883bd66cb::3c9::68aa", "source_doc": "Technology_Risk_Management_Guidelines_2021.pdf", "page": 5, "passage": "1.4 The revised MAS Technology Risk Management Guidelines set out technology\nrisk management principles and best practices for the financial sector, to guide FIs in the\nfollowing:\n(a) Establish Sound and Robust Technology Risk Governance and Oversight\nThe board of directors and senior management at an FI play an integral part in\nthe oversight and management of technology risk. The board of directors and\nsenior management should cultivate a strong risk culture, and ensure the\nestablishment of a sound and robust technology risk management framework.\n(b) Maintain Cyber Resilience\nStrong cyber resilience is critical for sustaining trust and confidence in financial\nservices. FIs should adopt a defence-in-depth approach to strengthening cyber\nresilience. It is also important that FIs establish and continuously improve their\nIT processes and controls to preserve confidentiality, integrity and availability of\ndata and IT systems.\nMonetary Authority of Singapore 5"}, {"chunk_id": "2b8959e883bd66cb::3d5::5f88", "source_doc": "Technology_Risk_Management_Guidelines_2021.pdf", "page": 12, "passage": "4.1.4 The framework should also encompass the following components:\nrisk identification - identify threats and vulnerabilities to the FI and\ninformation assets;\nrisk assessment - assess the potential impact and likelihood of threats\nand vulnerabilities to the FI and information assets;\nrisk treatment - implement processes and controls to manage technology\nrisks posed to the FI and protect the confidentiality, integrity and\navailability of information assets; and\nrisk monitoring, review and reporting - monitor and review technology\nrisks, which include risks that customers are exposed to, changes in\nbusiness strategy, IT systems, environmental or operating conditions; and\nreport key risks to the board of directors and senior management.\n\n4.1.5 As business and IT environments, as well as the cyber threat landscape, tend to\nevolve over time, the FI should review the adequacy and effectiveness of its risk\nmanagement framework regularly.\nMonetary Authority of Singapore 12"}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::38f::d3ab", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 32, "passage": "Transfer of personal data outside Singapore\n26.-(1) An organisation must not transfer any personal data to a\ncountry or territory outside Singapore except in accordance with\nrequirements prescribed under this Act to ensure that organisations\nprovideastandardofprotectiontopersonaldatasotransferredthatis\ncomparable to the protection under this Act. (2) The Commission may, on the application of any organisation,\nby written notice exempt the organisation from any requirement 33 Act 2012 2020Ed.\nprescribed pursuant to subsection (1) in respect of any transfer of\npersonal data by that organisation. (3) An exemption under subsection (2) -\n(a) may be granted subject to such conditions as the\nCommission may specify in writing; and\n(b) neednotbepublishedintheGazetteandmayberevokedat\nany time by the Commission. (4) The Commission may at any time add to, vary or revoke any\ncondition imposed under this section."}, {"chunk_id": "0e996ae99839f19e::21c::b941", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 3, "passage": "PART 6\nCARE OF PERSONAL DATA\n23. Accuracy of personal data\n24. Protection of personal data\n25. Retention of personal data\n26. Transfer of personal data outside Singapore\nPART 6A\nNOTIFICATION OF DATA BREACHES\n26A. Interpretation of this Part\n26B. Notifiable data breaches\n26C. Duty to conduct assessment of data breach\n26D. Duty to notify occurrence of notifiable data breach\n26E. Obligations of data intermediary of public agency\n\n3 Act 2012 2020Ed.\n\nPART 7\nSection\n27. to 32. [Repealed]\n\nPART 8\n33. [Repealed]\n34. [Repealed]\n35. [Repealed]"}], "rationale": "MAS TRM Guidelines regulate technology risk management at MAS-supervised FIs (governance, ICT, outsourcing, cybersecurity). PDPA regulates personal data handling. The two regimes co-apply to MAS-supervised FIs that are also PDPA-bound organisations, but operate in disjoint domains. TRM's data confidentiality controls satisfy PDPA Part 6 (care of personal data) as a side effect, but the obligations are cumulative not conflicting. Easy hard negative.", "would_conflict_if": ["TRM Guidelines required cross-border ICT-incident data sharing that PDPA s 26 would prohibit — TRM expressly contemplates PDPA compliance."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:d1c83d4091b5527f9fb25d54", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}, {"chunk_id": "4b4c3c417dc293ba::170::3d86", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": null, "passage": "MAS Notice PSN02\n5 December 2019\nNOTICE TO HOLDERS OF PAYMENT SERVICE LICENCE (DIGITAL PAYMENT TOKEN\nSERVICE)\nMONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186\nPREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF\nTERRORISM - HOLDERS OF PAYMENT SERVICE LICENCE (DIGITAL PAYMENT TOKEN\nSERVICE)\n______________________________________________________________________"}], "rationale": "AU_ASIC_CRYPTO (financial-product classification of digital assets under the Corporations Act) and SG_PSA_DPT (Singapore's DPT-licence AML notice under the Payment Services Act 2019) both regulate crypto-asset service provision but apply distinct perimeters. A focuses on whether the asset is a financial product; B focuses on DPT-licensee AML obligations. The cited passages don't show overlapping obligations on the same entity."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:dc3cb8c4fbf98c2c23bcbff8", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "ASIC crypto-asset guidance"}, "regime_b": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU AML/CTF Act + Rules"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}], "evidence_b": [{"chunk_id": "254ca2d92d196180::369::b111", "source_doc": "Anti-Money Laundering act 2006.pdf", "page": 98, "passage": "Part 2 Identification procedures etc. Division 2 Identification procedures for certain pre-commencement customers\nSection 29\n(b) after the commencement of this section, a suspicious matter\nreporting obligation arises for the reporting entity in relation\nto the customer. Note 1: For suspicious matter reporting obligation, see section 41. Note 2: For tipping-off offences, see section 123. Requirement\n(2) The reporting entity must:\n(a) take such action as is specified in the AML/CTF Rules; and\n(b) do so within the time limit allowed under the AML/CTF\nRules. Civil penalty\n(3) Subsection (2) is a civil penalty provision. Interpretation\n(4) For the purposes of this section, assume that Part 1 had been in\nforce at all material times before the commencement of this\nsection.\n80 Anti-Money Laundering and Counter-Terrorism Financing Act 2006 Identification procedures etc."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): ASIC's crypto-asset INFO 225 / RG 282 guidance and Australian AML/CTF Act + Rules (binding instruments) operate in disjoint regulatory domains at the obligation level. ASIC crypto-asset guidance addresses securities-law treatment; AML/CTF Act addresses AML — disjoint. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:484edbb627ebea5c1a51dcbb", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 234"}, "regime_b": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU Travel Rule (IFTI)"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "ddcef7b1f5780c26::5d3::163e", "source_doc": "CPS_234_Information_Security.pdf", "page": null, "passage": "Prudential Standard CPS 234\nInformation Security\nObjectives and key requirements of this Prudential\nStandard\nThis Prudential Standard aims to ensure that an APRA-regulated entity takes\nmeasures to be resilient against information security incidents (including cyber-\nattacks) by maintaining an information security capability commensurate with\ninformation security vulnerabilities and threats.\nA key objective is to minimise the likelihood and impact of information security\nincidents on the confidentiality, integrity or availability of information assets,\nincluding information assets managed by related parties or third parties.\nThe Board of an APRA-regulated entity is ultimately responsible for ensuring that\nthe entity maintains its information security.\nThe key requirements of this Prudential Standard are that an APRA-regulated entity\nmust:\n clearly define the information security-related roles and responsibilities of the\nBoard, senior management, governing bodies and individuals;\n maintain an information security capability commensurate with the size and\nextent of threats to its information assets, and which enables the continued\nsound operation of the entity;\n implement controls to protect its information assets commensurate with the\ncriticality and sensitivity of those information assets, and undertake\nsystematic testing and assurance regarding the effectiveness of those controls;\nand\n notify APRA of material information security incidents.\nCPS 234 - 1\n\nAuthority"}], "evidence_b": [{"chunk_id": "561fc09c315f8349::45d::68bb", "source_doc": "Money transferred to and from overseas International funds transfer instruction (IFTI) reports.pdf", "page": null, "passage": "In\nan IFTI-E: e the transfer instruction is carried out or passed on electronically https://www.austrac.gov.au/business/core-guidance/reporting/money-transferred-and-overseas-international-funds-transfer-instruction-ifti-reports 2/6 25/06/2025, 23:15 Money transferred to and from overseas: International funds transfer instruction (IFTI) reports | AUSTRAC e the transfer is within the same financial institution or between financial\ninstitutions, such as banks, building societies or credit unions. An IFTI-E can be either:\ne outgoing - the ordering institution accepts the instruction in Australia and transfers money to the payee via a beneficiary institution overseas e incoming - the ordering institution accepts the instruction overseas and\ntransfers money via a beneficiary institution in Australia. Information required in IFTI-E reports\nIFTI-E reports must include details about everyone involved in the transfer:\ne the payer - the business, organisation or individual who instructs the ordering\ninstitution to transfer money\ne the ordering institution - the institution that accepts the transfer instruction"}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): APRA CPS 234 information security standard and AUSTRAC IFTI / EFTI travel-rule reporting operate in disjoint regulatory domains at the obligation level. Info-sec vs AML travel rule — disjoint obligation surfaces. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:28:54Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:2fdb969d5a315b961245793a", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The EU_PSD2 passages regulate the technical authentication requirements for payment services, specifically strong customer authentication and security credentials (chunks 64f, 31a). The INT_IOSCO_GENERAL passages discuss the 'Objectives and Principles of Securities Regulation' and general disclosure standards for securities markets (chunk 455). The obligations in the EU regime relate to payment initiation and security, while the IOSCO regime relates to securities regulation and disclosure. There is no specific obligation in the EU payment regulation that conflicts with a specific obligation in the IOSCO securities regulation; they regulate distinct domains of financial activity."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:97b431cc89d0d367e4ffb42c", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "Market Abuse Regulation"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiFID II"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::1bd::d04c", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 14\nProhibition of insider dealing and of unlawful disclosure of inside information\nA person shall not:\n(a) engage or attempt to engage in insider dealing;\n(b) recommend that another person engage in insider dealing or induce another person to engage in insider dealing; or\n(c) unlawfully disclose inside information.\n\nArticle 15\nProhibition of market manipulation\nA person shall not engage in or attempt to engage in market manipulation."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::49c::69f4", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 53, "passage": "Member States shall require that investment firms and market operators operating an MTF or an OTF establish,\npublish and maintain and implement transparent and non-discriminatory rules, based on objective criteria, governing\naccess to its facility.\n4. Member States shall require that investment firms and market operators operating an MTF or an OTF have\narrangements to identify clearly and manage the potential adverse consequences for the operation of the MTF or OTF,\nor for the members or participants and users, of any conflict of interest between the interest of the MTF, the OTF, their\nowners or the investment firm or market operator operating the MTF or OTF and the sound functioning of the MTF or\nOTF.\n5. Member States shall require that investment firms and market operators operating an MTF or OTF comply with\nArticles 48 and 49 and have in place all the necessary effective systems, procedures and arrangements to do so.\n6. Member States shall require that investment firms and market operators operating an MTF or an OTF clearly inform\nits members or participants of their respective responsibilities for the settlement of the transactions executed in that\nfacility."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "rationale": "MiFID II and MAR are companion EU market-conduct instruments: MiFID II provides authorisation and conduct rules for investment firms; MAR overlays market-abuse prohibitions on the same population. MiFID II Article 16 organisational requirements explicitly include systems and controls designed to detect market abuse — the MAR / MiFID II interaction is by design. Hard negative.", "would_conflict_if": ["MAR Art 16 STOR (suspicious transaction or order report) confidentiality rules contradicted MiFID II Art 24 client-information rules — designed to be cumulative, not conflicting."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:47:18Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:51cbb7e0d6c35905820eb08e", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The AU_ATO_CRYPTO passage discusses the Australian tax treatment and regulation of crypto assets, specifically noting the government's reform agenda and the tax reporting of crypto assets by Australians. The INT_IOSCO_GENERAL passage outlines the methodology and objectives of the International Organization of Securities Commissions (IOSCO), focusing on international standards for securities regulation and cooperation among securities authorities. The two regimes regulate distinct domains: one is a domestic tax and regulatory framework for crypto assets, while the other is an international standard-setting body's methodology for securities regulation. There is no specific obligation in the AU_ATO_CRYPTO regime that conflicts with a specific obligation in the INT_IOSCO_GENERAL regime, nor do the passages indicate an overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:214237cb25f2f26792467545", "label": "conflict", "regime_a": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "evidence_a": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "EU_REVERSE_SOLICITATION (EU MiCA reverse-solicitation exemption — third-country firms may provide crypto-asset services without MiCA authorisation when EU client takes the initiative) and SG_PSA_DPT (Singapore PSA DPT-service licence). Whether a Singapore DPT-licensee serving EU clients can rely on the reverse-solicitation exemption turns on FACTS not pinned down in the regulations themselves: the firm's marketing reach, solicitation history, and channel of customer acquisition. ESMA's guidance treats this as a fact-specific inquiry that must be documented and may be challenged.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:04Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:42:00Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:2be7e478470e8ce815245f3b", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::45b::7c2f", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "However, to ensure market integrity and public trust, it is critical that all\nsingle-labelled SCS meet the same regulatory requirements. As a result, we support the\nMAS's proposal for single-labelled SCS, but only under the condition that non-banks would\nbe also subject the same regulatory requirements for their SCS issuance services. Moreover, we would recommend that MAS adopts the term \"regulated stablecoins\" as we\nfind that it reflects MAS's aspiration to develop a digital assets ecosystem by introducing a\nrobust regulatory framework for SCS. In parallel, we believe that it would be beneficial if\nSCS issuers would be able to add on the single label of SCS, e.g. \"regulated stablecoin -\nCompany A\". This could help customers differentiate their SCS offerings, encourage\ncompetition and consequently attract more issuers and contribute to the development of\nthe digital asset ecosystem. Question 5. MAS seeks comments on whether the proposed reserve asset requirements are\nappropriate, and whether there may be unintended consequences that may affect the\ndevelopment of Singapore's digital asset ecosystem."}, {"chunk_id": "7c04f2a0bd85290a::40f::805d", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 37, "passage": "We believe that a single label for bank and non-bank issued SCS is sufficient as the\npurpose of the label is to highlight to customers that a given issuer is adequately\nregulated and a single label serves that purpose. We believe the term 'regulated 15 August 2023 | 50\nstablecoin' is likely the clearest option for the purpose of achieving the aforementioned\npurpose. Perhaps 'locally regulated stablecoin' might also be applied to distinguish a\nstablecoin regulated by MAS from stablecoins which are regulated elsewhere using\ndifferent standards. Question 5. MAS seeks comments on whether the proposed reserve asset requirements are\nappropriate, and whether there may be unintended consequences that may affect the\ndevelopment of Singapore's digital asset ecosystem. We believe that the proposed reserve asset requirements are appropriate, however\nlimiting the pegs to the Singaporean dollar and Group of Ten Currencies, seems short\nsighted as it precludes SCS projects backed by other important currencies like CNH from\nbeing regulated."}], "rationale": "The Basel Crypto regime (Regime A) focuses on capital requirements, risk-weighting exposures to financial institutions, and supervisory equivalence for securities firms and other entities (chunk_ids 32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). The Singapore Stablecoin regime (Regime B) focuses on the issuance, reserve requirements, and regulatory perimeter of Single-Currency Stablecoins (SCS) under the Payment Services Act (chunk_ids 7c04f2a0bd85290a::45b::7c2f, 7c04f2a0bd85290a::40f::805d). The obligations in Regime A relate to the prudential treatment of bank exposures and capital adequacy, while Regime B addresses the consumer protection and market integrity of specific tokenized products. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B; rather, they regulate distinct aspects of the financial system (banking capital vs. stablecoin issuance). Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:48:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:acce8484bba1f4af19b3eeb4", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLD6"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "rationale": "The evidence for AU_APRA_CPS230 focuses on operational resilience, business continuity, and the management of service providers to ensure critical operations continue through disruptions (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c). The evidence for EU_AMLD6 (chunk_id 85307f9e2a040982::14a::134d) references a directive amending financial sector regulations regarding digital operational resilience. While both regimes address operational resilience, the specific obligations and contexts differ. AU_APRA_CPS230 mandates internal management of operational risks and service providers, whereas EU_AMLD6 appears to address broader digital resilience frameworks for the financial sector. There is no specific obligation in one regime that directly conflicts with a specific obligation in the other; rather, they regulate similar domains (operational resilience) with potentially complementary or distinct requirements."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:11:37Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:cbc41bf16d0d786b649863d5", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "018117ef1e757630::4b5::9ef5", "source_doc": "Strengthening_AMLCFT_Controls_DPT_SPs.pdf", "page": null, "passage": "Guidelines\n• MAS' surveillance efforts are • Existing VASPs operating in\nfocused on: (a) detecting and Singapore were required to notify\nLicensing\ndeterring unlicensed DPT activities MAS and submit licence\nSurveillance and\nin Singapore; and (b) leveraging applications by 28 Jul 2020.\ndata and blockchain analytics to Supervision\nidentify higher risk entities. • Applicants expected to\ndemonstrate understanding and\nability to mitigate ML/TF risks. Slide 5 (III) AML/CFT requirements for DPT sector\nAML/CFT requirements for digital payment token (DPT) service in Singapore\n• AML/CFT requirements are set out in MAS Notice PSN02 (issued 5 Dec 2019) and Guidelines to PSN02 (issued on 16 Mar 2020). Amendments to the Payment Services Act were passed in Parliament in Jan 2021 to expand the scope of DPT services and\nfurther updates to Notice PSN02 and Guidelines are in train to apply AML/CFT requirements to the newly scoped-in DPT services.\n• Entities that (a) deal in DPT; (b) facilitate the exchange of DPT; (c) facilitate the transmission of DPT; (d) and/or provide custodian\nwallet services, will therefore be required to be licensed as DPT service providers, and comply with the AML/CFT requirements."}], "rationale": "The EU regime (Regulation (EU) 2023/1113) imposes obligations on payment service providers to accompany transfers of funds with information on the payer and payee to ensure traceability for AML/CFT purposes (c0300673081f7232::279::1918). The Singapore regime (MAS Notice PSN02) establishes AML/CFT requirements for Digital Payment Token (DPT) service providers, requiring them to comply with MAS Notice PSN02 and Guidelines (018117ef1e757630::4b5::9ef5). The passages describe distinct regulatory frameworks for different jurisdictions (EU vs. Singapore) that apply to different asset classes (transfers of funds/crypto-assets vs. DPT services). There is no specific obligation in the EU regime that pushes against a specific obligation in the Singapore regime; rather, they are separate national implementations of AML/CFT standards. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:145ab28311eb5c5c8d0326e2", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::6a8::d132", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 36, "passage": "That legal basis may contain specific provisions to adapt the application of\nrules of this Regulation, inter alia: the general conditions governing the lawfulness of processing by the controller; the\ntypes of data which are subject to the processing; the data subjects concerned; the entities to, and the purposes for\nwhich, the personal data may be disclosed; the purpose limitation; storage periods; and processing operations and\nprocessing procedures, including measures to ensure lawful and fair processing such as those for other specific 4.5.2016 EN Official Journal of the European Union L 119/37\nprocessing situations as provided for in Chapter IX. The Union or the Member State law shall meet an objective of\npublic interest and be proportionate to the legitimate aim pursued.\n4. Where the processing for a purpose other than that for which the personal data have been collected is not based\non the data subject's consent or on a Union or Member State law which constitutes a necessary and proportionate\nmeasure in a democratic society to safeguard the objectives referred to in Article 23(1), the controller shall, in order to\nascertain whether processing for another purpose is compatible with the purpose for which the personal data are\ninitially collected, take into account, inter alia:\n(a) any link between the purposes for which the personal data have been collected and the purposes of the intended\nfurther processing;\n(b) the context in which the personal data have been collected, in particular regarding the relationship between data\nsubjects and the controller;\n(c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to"}, {"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "08b3db1cc7362f25::3bb::5dba", "source_doc": "Guidance-Correspondent-Banking-Services.pdf.coredownload.pdf", "page": null, "passage": "FATF GUIDANCE\nCORRESPONDENT\nBANKING SERVICES\nOCTOBER 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on correspondent banking services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/correspondent-banking-services.html\n© 2016 FATF/OECD."}], "rationale": "EU_GDPR (cross-border data transfer principles) and INT_FATF_GENERAL (FATF AML/CFT general standards requiring customer-identification and cross-border information sharing). FATF Recommendation 16 (travel rule) and CBDR transmission requirements mandate sharing of personal data across borders; GDPR Chapter V restricts. Operationally resolvable via Art. 6(1)(c) and Chapter V mechanisms. Same conflict shape as EU TFR ↔ GDPR in the careful cohort.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:46Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:35:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:47e6dda4ad26b488e6fcb175", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "The EU MICA Title IV EMT passages regulate the content and liability of crypto-asset white papers for issuers of e-money tokens and asset-referenced tokens (e.g., Article 51, Article 52, Recital 69). The SG PSA GENERAL passages discuss the regulatory scope of Payment Services licenses in Singapore, specifically regarding Digital Payment Token Services (DPT) and the licensing of entities like Binance (e.g., 'MAS seeks comments on the regulatory scope', 'MAS may wish to provide recognition for foreign SCS operating in SG'). The obligations in the EU regime relate to the disclosure of information in white papers, while the obligations in the SG regime relate to the licensing and supervision of entities providing DPT services. These are distinct regulatory domains; the EU rules do not impose obligations on Singaporean entities, nor do the SG rules impose obligations on EU issuers in a way that creates a conflict with the EU's internal requirements."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.75, "record_type": "conflict", "pair_id": "conflict:a0c69b375194f834c53a40f8", "label": "conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "evidence_a": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "20d526d712753652::1a4::2e6e", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Notabene commend's the Monetary Authority of Singapore (MAS) for proposing a\ncomprehensive and detailed regulatory approach for Digital Token Service Providers\n(DTSPs) under the Financial Services and Markets Act 2022. Our comments focus on\nthe alignment of these notices and guidelines with international standards,\nparticularly in light of Financial Action Task Force (FATF) Recommendations,\nincluding the Travel Rule."}], "rationale": "SG_FSMA_DTSP (extraterritorial DTSP scope) and EU_AMLR_TFR (EU AML regulation and TFR for crypto-asset transfers). Whether an EU-licensed CASP also falls within SG DTSP scope when transmitting crypto value to SG counterparties depends on facts about the service-delivery channel and target market — fact-sensitive determination.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:19Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:18:03Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:4d7877f62c417a21654ad65e", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The EU_PSD2 passages regulate the technical authentication requirements for payment service providers, specifically defining 'strong customer authentication' and the use of 'personalised security credentials' (chunk_ids adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b). The MAS_TRM passages discuss the application of principles-based guidelines to licensees, including the TRM Guidelines and Fit and Proper criteria, and do not contain any obligations regarding authentication methods or security credentials (chunk_id 20d526d712753652::401::f956). The regimes regulate distinct aspects of financial services—technical payment security standards versus general licensing and governance principles—resulting in no overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:39:42Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:4e2e4290d1158192e8663bd8", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::41f::546c", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 24, "passage": "3.1 Standard AFSL Obligations\nAustralian financial services licence\n(a) A platform provider must hold an AFSL authorising them to issue and deal in digital asset facilities.\n(b) A platform provider is exempt from holding an AFSL for digital asset facilities if:\n(i) the total value of platform entitlements held by any one client of the platform provider does\nnot exceed $1,500 at any one time; and\n(ii) the total amount of assets held by the platform provider does not exceed $5 million at any\ntime.\nInfo Box 3 Low value exemption\nThe risks with digital asset facilities are correlated to the size and scale of the asset holding role of\nthe platform provider. Accordingly, a 'low-value facility' exemption would be introduced, similar to\nthe 'low value facility' exemption for non-cash payment facilities. It would apply to digital asset\nfacilities holding less than $1,500 per customer and less than $5 million in total.40 This exemption\nis intended to allow for innovation and experimentation in the early stages of developing a novel\nservice offering."}, {"chunk_id": "550958b067dc6726::74a::7ef1", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 26, "passage": "46 For information on ASIC's interpretation of this obligation, see ASIC PF 209 Australian financial services\nlicence conditions\nLicensing digital asset intermediaries | 23\n\n(vi) having the financial,47 technological, and human resources to carry out and supervise the\nfinancial service covered by the AFSL,\n(vii) having a dispute resolution system48 and compensation arrangements for retail clients for\nloss or damage suffered due to breaches of obligations, and\n(viii) maintaining a risk management system.\nFinancial requirements\n(g) A platform provider must meet:\n(i) the standard solvency and positive net asset requirements,49\n(ii) the standard cash needs requirement, and\n(iii) a net tangible assets (NTA) requirement for holding cash or cash equivalents and holding\nliquid assets of at least:\n• 0.5 per cent of the value of the facility (if using a sub-custodian digital asset facility that\nhas $5m NTA),50 or\n• $5 million (if performing the custody function).\nInfo Box 6 Financial requirements\nAFSL holders have obligations to meet 'financial requirements'. These requirements are typically\ntailored for different financial products through ASIC legislative instruments. The NTA obligation is\nto address the costs of orderly wind-up in the event the provider fails.51\nA key issue with digital assets is concentration risk (see Info Box 11 Additional Standards for token\nholders). The proposed financial requirements balance the need to avoid concentration of digital\nassets among a small number of custodians with the need to ensure robust NTA. It sets the\nrequired level of NTA at the greater of $5 million or 0.5% of the value of the assets held by the\nfacility.52 This arrangement ensures that as a facility expands, and the operational risk exposure of\nthe platform provider grows, the provider will maintain a corresponding level of financial\nresources."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}, {"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "rationale": "The AU_ASIC_AFSL regime regulates the licensing and conduct of financial services providers (specifically platform providers and intermediaries) in Australia, focusing on financial product definitions, AFSL requirements, and financial obligations (chunk_ids 550958b067dc6726::41f::546c, 550958b067dc6726::74a::7ef1). The FATF_R16 regime regulates Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) standards globally, focusing on customer due diligence, digital identity, and red flag indicators for money laundering (chunk_ids 5d489619a0fb9ecf::377::a91e, 85240528438654b9::396::417b). The obligations in the AU_ASIC_AFSL passage relate to the operational and financial requirements of holding an Australian Financial Services Licence, while the FATF_R16 passages relate to the global AML/CFT framework and digital identity. These are distinct regulatory domains; the AU_ASIC_AFSL obligations do not impose specific AML/CFT requirements that conflict with the FATF R16 standards, nor do the FATF R16 standards impose specific financial licensing requirements that conflict with the AU_ASIC_AFSL regime. Therefore, the regimes are non-conflicting."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:32:33Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:090fe94f3692ded40b17790c", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "66d049e24f0863da::3f7::aec8", "source_doc": "Superannuation-Reporting-Standards-RIS.pdf", "page": 1, "passage": "1 INTRODUCTION\nThis Regulation Impact Statement (RIS) addresses the Australian Prudential Regulation\nAuthority's (APRA's) proposed introduction of new reporting standards applying to trustees of\nregistrable superannuation entities (RSE licensees). APRA is the prudential regulator of the superannuation, banking and insurance industries. Its\nmission is to ensure that, under all reasonable circumstances, financial promises made by APRA-\nregulated institutions are met within a stable, efficient and competitive financial system. APRA\ncarries out this mission through a multi-layered prudential framework that encompasses\nlicensing and supervision of institutions. For many years, APRA has had the power to make\nprudential standards implementing this framework for the banking and insurance industries. APRA is also empowered to make reporting standards under the Financial Sector (Collection of\nData) Act 2001 (FSCODA), which require regulated institutions to submit specified data through\nvarious reporting forms."}], "evidence_b": [{"chunk_id": "25cbbd878a1b21d3::4f8::561c", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 19, "passage": "8. In a baseline scenario, without the guidelines:\ni) where a client located or established in the EU initiates a crypto-asset service at\nits own exclusive initiative with a third-country firm, the authorisation requirements\nunder Article 59 of MiCA do not apply to the provision of that crypto-asset service\nor activity by the third-country firm to that client, including a relationship specifically\nrelating to the provision of that crypto-asset service or activity;\nii) a third-country firm may not rely on the reverse solicitation exemption where such\nfirm, including through an entity acting on its behalf or having close links with such\nthird-country firm or any other person acting on behalf of such entity, solicits clients\nor prospective clients in the EU;\niii) solicitation of EU clients for the purposes of ii) above should be assessed\nregardless of the means of communication used for the solicitation, promotion or\nadvertising in the Union;\niv) where a third-country firm has been contacted by a client at its own exclusive\ninitiative, the third-country firm is entitled to market new crypto-assets or crypto-\nasset services to that client, if such new crypto-assets or crypto-asset services are\nof the same type as the ones initially requested by the client."}], "rationale": "The AU_APRA_PRUDENTIAL passages describe APRA's regulatory framework for Australian financial institutions, including licensing, supervision, and prudential standards for banks, insurers, and superannuation entities (chunk 66d049e24f0863da::3f7::aec8). The EU_REVERSE_SOLICITATION passages describe the conditions under which third-country crypto-asset service providers can operate in the EU without authorisation, specifically focusing on 'reverse solicitation' where the client initiates the relationship (chunk 25cbbd878a1b21d3::4f8::561c). The obligations and regulated entities in the two regimes are distinct; APRA regulates Australian financial institutions, while the EU regime regulates third-country crypto-asset service providers targeting EU clients. There is no specific obligation in APRA's prudential framework that conflicts with the EU's reverse solicitation exemption for crypto-assets."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:34:26Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:5ec85b2246792db9e5738b04", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "rationale": "The evidence from APRA CPS 230 focuses on operational risk management, resilience, and the management of service providers (chunk_ids f296a7e0bead93df::4a5::9828, f296a7e0bead93df::5e9::d5f4). The evidence from the EU AMLA Directive focuses on the institutional framework for anti-money laundering and countering the financing of terrorism (chunk_id df546f2364aaf9e2::25a::6ab3). The obligations in the AMLA regime relate to supervisory cooperation and information exchange regarding financial crime, whereas the APRA regime relates to the resilience of critical operations and internal risk management. These are distinct regulatory domains with no apparent overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:32:03Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:4a680fffb2d71c32716ce921", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3c9eb3a25c93f394::474::4786", "source_doc": "CP_3rd_Package_MarketAbuse_InvestorProtection_OpRes.pdf", "page": null, "passage": "Several other EU Directives include pending technical standards or guidelines intended\nto specify measures for access controls in the context of ICT security. Under the\nNetwork and Information Security Directive (EU) 2022/2555 (NIS2), the Commission is\nempowered to prepare implementing acts on the 'technical and methodological\nrequirements' for a range of measures, including access control policies (as well as\npolicies regarding the use of cryptography)19. Similarly, as part of Directive (EU)\n2022/2557 (Critical Entities Regulation), the Commission is also responsible for the\n19 Commission Implementing Act pursuant to Art. 21(5) of Directive (EU) 2022/2555 (NIS2) (link) preparation of guidelines on a range of resilience measures for so-called 'Critical\nEntities' which would include 'access controls20'.\n131. Although the draft level 2 and 3 measures under NIS2, which will enter into application\non 18 October 2024, are still unavailable as of the publication of this paper, ESMA will\nconsider alignment only insofar as those implementing measures are relevant to the\nmandate and the area of financial services more broadly.\n132."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}], "rationale": "The EU_NIS2 passage discusses the technical and methodological requirements for access control policies and ICT security measures (chunk 3c9eb3a25c93f394::474::4786). The FATF_R16 passage introduces the FATF as an inter-governmental body developing policies to protect the global financial system against money laundering and terrorist financing (chunk 5d489619a0fb9ecf::377::a91e). The regimes regulate distinct domains: EU_NIS2 focuses on cybersecurity and network resilience for operators of essential services, while FATF_R16 focuses on AML/CFT standards. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:3d01d06da4da84b9a9f8fa83", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 230"}, "regime_b": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU Treasury DAP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "550958b067dc6726::51b::b09b", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 6, "passage": "5 KordaMentha, 'Token mapping: Response to Treasury consultation paper', March 2023. Introduction | 3 laws, digital asset platforms that do not deal in financial products are not subject to financial services\nlaws. The Government intends to introduce a regulatory framework aimed at addressing the significant risks\nand potential harms associated with digital asset platforms, while fostering innovation and safe usage\nof digital assets and distributed ledger technology. The framework outlined in this paper proposes to\nregulate digital asset platforms within the existing Australian financial services laws, while ensuring all\nconsumers and businesses have the opportunity to safely explore and share in any benefits of the\ntechnology. Key terms and concepts used throughout this paper\nUnderstanding the policy problem and the proposed regulatory solution requires an understanding of\nseveral key concepts and terms that are used throughout this paper. These concepts and terms aim to\nreduce the complexity of the paper's content, which necessarily covers topics across industries,\ntechnologies, and regulatory frameworks. They include some broad generalisations for descriptive\nconvenience and some precise technical descriptions for topics stakeholders have identified as causing\nregulatory uncertainty."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): APRA CPS 230 operational-risk management standard and AU Treasury Digital Asset Platforms framework operate in disjoint regulatory domains at the obligation level. APRA prudential standard vs Treasury platform-regulation proposal — disjoint frames. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:4dedf68eab7f32ed8ac692e4", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}], "rationale": "EU_AMLR_TFR (EU's AML framework extending AML/CFT to CASPs and mandating originator/beneficiary information for crypto transfers) and INT_FATF_VASP (FATF VASP guidance — AML/CFT standards for VAs and VASPs). The EU's TFR is the EU's binding implementation of FATF VASP/R16 standards; reinforcing relationship."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:14:16Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:3cf1caf492952571af876f18", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "rationale": "The regimes regulate distinct domains. Regime A (AU_ASIC_CRYPTO) governs the licensing and classification of crypto-assets and digital asset service providers under Australian financial services law (Corporations Act 2001). Regime B (INT_BASEL_CRYPTO) establishes prudential capital requirements and risk-weighting methodologies for banks' exposures to financial institutions. The evidence shows no specific obligation in the Basel framework that conflicts with ASIC's guidance on crypto-assets; rather, they address separate regulatory objectives—consumer protection and market integrity versus bank solvency and capital adequacy."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:18:44Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:7edb9c3bbf60f69642445445", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "rationale": "The evidence for the Australian regime (AU_ATO_CRYPTO) focuses on the taxation of crypto assets and the token mapping process (chunk_id e6bb47e92e88e16c::567::36c4). The evidence for the European regime (EU_EMD2) concerns digital operational resilience for the financial sector (chunk_id 85307f9e2a040982::14a::134d). The obligations and subject matter of the two regimes are distinct; one regulates tax treatment and ecosystem mapping, while the other regulates operational resilience in the financial sector. Therefore, there is no overlap of obligations or conflict between the two."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:37:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9f9b01663919f70de40be775", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "66d049e24f0863da::3f7::aec8", "source_doc": "Superannuation-Reporting-Standards-RIS.pdf", "page": 1, "passage": "1 INTRODUCTION\nThis Regulation Impact Statement (RIS) addresses the Australian Prudential Regulation\nAuthority's (APRA's) proposed introduction of new reporting standards applying to trustees of\nregistrable superannuation entities (RSE licensees). APRA is the prudential regulator of the superannuation, banking and insurance industries. Its\nmission is to ensure that, under all reasonable circumstances, financial promises made by APRA-\nregulated institutions are met within a stable, efficient and competitive financial system. APRA\ncarries out this mission through a multi-layered prudential framework that encompasses\nlicensing and supervision of institutions. For many years, APRA has had the power to make\nprudential standards implementing this framework for the banking and insurance industries. APRA is also empowered to make reporting standards under the Financial Sector (Collection of\nData) Act 2001 (FSCODA), which require regulated institutions to submit specified data through\nvarious reporting forms."}], "evidence_b": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}], "rationale": "The APRA passage describes a prudential framework for regulated institutions (ADIs, insurers, RSE licensees) focused on capital requirements, licensing, and supervision (chunk 66d049e24f0863da::3f7::aec8). The EU_PSD2 passage describes a directive on payment services, specifically focusing on strong customer authentication and security measures for payment service providers (chunk adb1a81b9cecaf8c::64f::f5ad). The obligations in the APRA regime relate to prudential supervision and capital adequacy, while the obligations in the EU_PSD2 regime relate to payment service security and authentication. These are distinct regulatory domains with no apparent overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:9b980d6b9643503cd0ad9098", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::3c5::d461", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 33, "passage": "80. Despite the many and frequently changing marketing terms and innovative\nbusiness models developed in this sector, the FATF envisions very few VA\narrangements without VASPs involved at some stage if countries apply the\ndefinition correctly. Countries should take particular care to assess any claims that\nbusinesses may make as to models of decentralization or distributed services, and\nconduct their own assessment of the business model in line with its risk and their\nability to mitigate these risks.\n\n81. As previously stated, the FATF Standards are technology neutral. As such, the FATF\ndoes not seek to regulate the technology that underlies VAs or VASP activities.\nRather the FATF seeks to regulate natural or legal persons behind such technologies\n\n32  UPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS\nthat conduct as a business the aforementioned VASP activities on behalf of another\nnatural or legal person."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "INT_FATF_VASP (FATF AML standards for VAs/VASPs) and INT_IOSCO_GENERAL (IOSCO securities regulation principles). Both are international standards bodies; FATF addresses AML/CFT, IOSCO addresses securities-regulation conduct and market integrity. They publish coordinated international guidance, often jointly, on crypto-related concerns. Aligned pillars of international financial regulation."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T17:02:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:c48e80164eb04baeda3b77bf", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}, {"chunk_id": "33d059aa86716ddd::4ed::8511", "source_doc": "2022_CP_Stablecoin_Regulatory_Approach.pdf", "page": 6, "passage": "3.5 A wide range of stablecoins currently exist, varying in terms of their asset-\npegging, as well as the mechanism that upholds the stability of the stablecoins' value\nagainst the pegged asset(s). MAS intends to focus its regulatory regime on:\nSingle-currency pegged stablecoins (SCS) - As compared to other types of\nstablecoins (such as those pegged to a basket of currencies or other\nassets such as commodities), SCS has a stronger use case for payment and\nsettlement.\nNon-SCS will continue to be subject to the existing DPT regime under the\nPS Act. MAS views such stablecoins as being less stable in nominal value\nand should be treated differently from SCS.\nIn addition, even among SCS, there is variation in the stabilisation\nmechanism. MAS views stablecoins which are algorithmically-pegged,\nunbacked or backed by other cryptocurrencies to be more susceptible to\nvolatility in value. Correspondingly, such stablecoins will also continue to\nbe treated as DPTs.\nSCS issued in Singapore - The immediate priority of MAS is to elevate the\nstandard of SCS issued in Singapore. Our regulatory perimeter is thus\nscoped based on MAS' ability to directly impose requirements on the\nreserve management, redemption policies and prudential standards of\nthe SCS issuer."}], "rationale": "The AU_PRIVACY regime regulates the cross-border disclosure of personal information to overseas recipients, requiring entities to ensure recipients comply with Australian Privacy Principles (APPs) or obtain specific consent (chunk_ids e9f6b0a9e797777d::5d6::e5ff, e9f6b0a9e797777d::4ba::1af3). The SG_STABLECOIN regime regulates the issuance and reserve requirements of Single-Currency Stablecoins (SCS) issued in Singapore, distinguishing them from other digital payment tokens (chunk_ids 58f45cd2ef3de201::36c::e2f6, 33d059aa86716ddd::4ed::8511). The obligations in the SG_STABLECOIN regime pertain to the asset backing and regulatory perimeter of the token itself, whereas the AU_PRIVACY obligations pertain to the handling of personal data during cross-border transfers. There is no specific obligation in the SG_STABLECOIN regime that pushes against the cross-border disclosure obligations in AU_PRIVACY. Therefore, the regimes regulate different domains and do not conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:53bca9b5bc652d0975bfdf02", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "9a96d4d1812f257a::2a6::2422", "source_doc": "161011-APRA-RIS-margining-risk-mitigation-final-assessment-second-pass.pdf", "page": 2, "passage": "2 APRA's prudential framework comprises prudential standards and prudential practice guides (PPGs). APRA is\nempowered to issue legally binding prudential standards that set out specific requirements with which APRA-regulated\ninstitutions - authorised deposit-taking institutions (ADIs), general insurers and life companies (collectively,\ninsurers) and registrable superannuation entity licensees (RSE licensees) - must comply. APRA also issues PPGs,\nwhich clarify APRA's expectations with regard to prudential matters. PPGs frequently discuss legal requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements."}], "rationale": "AU_APRA_CPS234 (APRA Information Security prudential standard) and AU_APRA_PRUDENTIAL (APRA's broader prudential framework). CPS 234 is part of APRA's prudential standards architecture; they operate together as parts of the same AU prudential framework."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:cf8b214a94574104f1029433", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU Travel Rule (IFTI)"}, "regime_b": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU Treasury DAP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "561fc09c315f8349::45d::68bb", "source_doc": "Money transferred to and from overseas International funds transfer instruction (IFTI) reports.pdf", "page": null, "passage": "In\nan IFTI-E: e the transfer instruction is carried out or passed on electronically https://www.austrac.gov.au/business/core-guidance/reporting/money-transferred-and-overseas-international-funds-transfer-instruction-ifti-reports 2/6 25/06/2025, 23:15 Money transferred to and from overseas: International funds transfer instruction (IFTI) reports | AUSTRAC e the transfer is within the same financial institution or between financial\ninstitutions, such as banks, building societies or credit unions. An IFTI-E can be either:\ne outgoing - the ordering institution accepts the instruction in Australia and transfers money to the payee via a beneficiary institution overseas e incoming - the ordering institution accepts the instruction overseas and\ntransfers money via a beneficiary institution in Australia. Information required in IFTI-E reports\nIFTI-E reports must include details about everyone involved in the transfer:\ne the payer - the business, organisation or individual who instructs the ordering\ninstitution to transfer money\ne the ordering institution - the institution that accepts the transfer instruction"}], "evidence_b": [{"chunk_id": "550958b067dc6726::51b::b09b", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 6, "passage": "5 KordaMentha, 'Token mapping: Response to Treasury consultation paper', March 2023. Introduction | 3 laws, digital asset platforms that do not deal in financial products are not subject to financial services\nlaws. The Government intends to introduce a regulatory framework aimed at addressing the significant risks\nand potential harms associated with digital asset platforms, while fostering innovation and safe usage\nof digital assets and distributed ledger technology. The framework outlined in this paper proposes to\nregulate digital asset platforms within the existing Australian financial services laws, while ensuring all\nconsumers and businesses have the opportunity to safely explore and share in any benefits of the\ntechnology. Key terms and concepts used throughout this paper\nUnderstanding the policy problem and the proposed regulatory solution requires an understanding of\nseveral key concepts and terms that are used throughout this paper. These concepts and terms aim to\nreduce the complexity of the paper's content, which necessarily covers topics across industries,\ntechnologies, and regulatory frameworks. They include some broad generalisations for descriptive\nconvenience and some precise technical descriptions for topics stakeholders have identified as causing\nregulatory uncertainty."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): AUSTRAC IFTI / EFTI travel-rule reporting and AU Treasury Digital Asset Platforms framework operate in disjoint regulatory domains at the obligation level. AML travel-rule vs proposed DAP framework — disjoint domains. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:917c039969e0959befd66f32", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 230"}, "regime_b": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 234"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "ddcef7b1f5780c26::5d3::163e", "source_doc": "CPS_234_Information_Security.pdf", "page": null, "passage": "Prudential Standard CPS 234\nInformation Security\nObjectives and key requirements of this Prudential\nStandard\nThis Prudential Standard aims to ensure that an APRA-regulated entity takes\nmeasures to be resilient against information security incidents (including cyber-\nattacks) by maintaining an information security capability commensurate with\ninformation security vulnerabilities and threats.\nA key objective is to minimise the likelihood and impact of information security\nincidents on the confidentiality, integrity or availability of information assets,\nincluding information assets managed by related parties or third parties.\nThe Board of an APRA-regulated entity is ultimately responsible for ensuring that\nthe entity maintains its information security.\nThe key requirements of this Prudential Standard are that an APRA-regulated entity\nmust:\n clearly define the information security-related roles and responsibilities of the\nBoard, senior management, governing bodies and individuals;\n maintain an information security capability commensurate with the size and\nextent of threats to its information assets, and which enables the continued\nsound operation of the entity;\n implement controls to protect its information assets commensurate with the\ncriticality and sensitivity of those information assets, and undertake\nsystematic testing and assurance regarding the effectiveness of those controls;\nand\n notify APRA of material information security incidents.\nCPS 234 - 1\n\nAuthority"}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): APRA CPS 230 operational-risk management standard and APRA CPS 234 information security standard are designed to coexist — obligations apply cumulatively without collision. Both APRA prudential standards on operational risk and information security — designed to coexist within the APRA framework. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:46:50Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:58054a1debb7a6c8b7a45baa", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "The evidence from Regime A (AU_AML_CTF) outlines general reporting obligations for suspicious matters and threshold transactions under the AML/CTF Act. The evidence from Regime B (SG_PSA_DPT) confirms that holders of a payment service licence providing digital payment token services are subject to AML/CFT requirements. The obligations in Regime A (reporting suspicious matters) are complementary to the obligations in Regime B (compliance with AML/CFT requirements for DPT services), reinforcing the same compliance goal without creating a specific conflict between the two regimes."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T06:30:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.78, "record_type": "non_conflict", "pair_id": "non_conflict:e17c7171e62d1f8e5cd5328c", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU AML/CTF (AUSTRAC guidance)"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title IV (EMT)"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}, {"chunk_id": "d38ec0ddcc912963::450::6872", "source_doc": "Reporting.pdf", "page": null, "passage": "'@ Australian Government Cee ee\nahem 8 eporting Home / Business / Core guidance / Reporting As a reporting entity you must report certain transactions and suspicious matters, and\nsubmit compliance reports to AUSTRAC. Everyone, including reporting entities, must\nreport cross-border movements of physical currency. Ongoing reporting obligations Threshold transaction reports You must submit threshold transaction reports (TTR) for transfers of A$10,000 or more\nin cash (or the foreign currency equivalent). TTRs are due within 10 business days after\nthe date of the transaction. International funds transfer instruction reports (IFTIs) You must submit international funds transfer instruction reports (IFTIs) for transfers of\nfunds of any value into or out of Australia, made either electronically or under a\ndesignated remittance arrangement. IFTIs are due within 10 business days after the\ntransfer instruction is sent or received. Suspicious matter reports (SMRs) You must submit suspicious matter reports (SMRs) when you have a suspicion that a\ncustomer or transaction is related to criminal activity."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::53d::70f2", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 13, "passage": "(66)\nIssuers of e-money tokens should be authorised either as a credit institution under Directive 2013/36/EU or as an\nelectronic money institution under Directive 2009/110/EC. E-money tokens should be deemed to be 'electronic\nmoney' as that term is defined in Directive 2009/110/EC and their issuers should, unless specified otherwise in\nthis Regulation, comply with the relevant requirements set out in Directive 2009/110/EC for the taking up,\npursuit and prudential supervision of the business of electronic money institutions and the requirements on\nissuance and redeemability of e-money tokens. Issuers of e-money tokens should draw up a crypto-asset white\npaper and notify it to their competent authority. Exemptions regarding limited networks, regarding certain\ntransactions by providers of electronic communications networks and regarding electronic money institutions\nissuing only a limited maximum amount of electronic money, based on the optional exemptions specified in\nDirective 2009/110/EC, should also apply to e-money tokens. However, issuers of e-money tokens should still be\nrequired to draw up a crypto-asset white paper in order to inform buyers about the characteristics and risks of\nthe e-money tokens and should also be required to notify the crypto-asset white paper to the competent authority\nbefore its publication."}, {"chunk_id": "491a2f0014d56ffb::321::0923", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 74, "passage": "Article 57\nVoluntary classification of e-money tokens as significant e-money tokens\n1.\nAn issuer of an e-money token, authorised as a credit institution or as an electronic money institution, or applying\nfor such authorisation, may indicate that it wishes for its e-money token to be classified as a significant e-money token.\nIn that case, the competent authority shall immediately notify such request of the issuer to EBA, to the ECB and, in the\ncases referred to in Article 56(3), second subparagraph, to the central bank of the Member State concerned.\nIn order for the e-money token to be classified as significant under this Article, the issuer of the e-money token shall\ndemonstrate, through a detailed programme of operations, that it is likely to meet at least three of the criteria set out in"}], "rationale": "MiCA Title IV regulates issuers of e-money tokens; AUSTRAC AML/CTF regulates reporting entities providing designated services in Australia. The two regimes apply to different regulated populations in different jurisdictions and address different subject matters. An Australian reporting entity is not an EMT issuer in the EU unless it separately establishes and authorises there (see the structural conflict labelled at AU_TREASURY_DAP :: EU_MICA_TITLE_IV_EMT). For an AU reporting entity simply performing AML/CTF compliance on its Australian-customer book, no MiCA Title IV obligation arises. This is the 'different domains' negative class — a deliberate non-conflict that the typed-seed queue surfaced as borderline.", "would_conflict_if": ["The AU AML/CTF entity itself issued a stablecoin marketed to EU residents — that scenario is the structural pair AU_TREASURY_DAP :: EU_MICA_TITLE_IV_EMT."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:03:53Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:47d1b01e274eacd1b109c1a5", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "66d049e24f0863da::3f7::aec8", "source_doc": "Superannuation-Reporting-Standards-RIS.pdf", "page": 1, "passage": "1 INTRODUCTION\nThis Regulation Impact Statement (RIS) addresses the Australian Prudential Regulation\nAuthority's (APRA's) proposed introduction of new reporting standards applying to trustees of\nregistrable superannuation entities (RSE licensees). APRA is the prudential regulator of the superannuation, banking and insurance industries. Its\nmission is to ensure that, under all reasonable circumstances, financial promises made by APRA-\nregulated institutions are met within a stable, efficient and competitive financial system. APRA\ncarries out this mission through a multi-layered prudential framework that encompasses\nlicensing and supervision of institutions. For many years, APRA has had the power to make\nprudential standards implementing this framework for the banking and insurance industries. APRA is also empowered to make reporting standards under the Financial Sector (Collection of\nData) Act 2001 (FSCODA), which require regulated institutions to submit specified data through\nvarious reporting forms."}], "evidence_b": [{"chunk_id": "c4024f4c4c1616cc::23d::700a", "source_doc": "AMLR_Regulation_EU_2024-1624.pdf", "page": 2, "passage": "(7) Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers\nof funds and certain crypto-assets and amending Directive (EU) 2015/849 (OJ L 150, 9.6.2023, p. 1).\n\n(8) Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing the Authority for\nAnti-Money Laundering and Countering the Financing of Terrorism and amending Regulations (EU) No 1093/2010, (EU)\nNo 1094/2010 and (EU) No 1095/2010 (OJ L, 2024/1620, 19.6.2024, http://data.europa.eu/eli/reg/2024/1620/oj)."}], "rationale": "The AU_APRA_PRUDENTIAL passage describes APRA's prudential framework, licensing, and supervision of financial institutions (chunk 66d049e24f0863da::3f7::aec8). The EU_AMLR_TFR passage references the EU's Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) framework and specific regulations regarding transfers of funds and crypto-assets (chunk c4024f4c4c1616cc::23d::700a). The obligations described in the EU passage relate to information accompanying transfers and AML/CFT compliance, whereas the APRA passage focuses on prudential standards, capital requirements, and supervision. These are distinct regulatory domains with no apparent overlap of obligations or conflicting requirements."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:45:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:53855cbbcaf8d3b1043c9bdd", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}, {"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "rationale": "The AU_TRAVEL_RULE passages discuss the Australian regulatory framework for digital currency exchanges and the implementation of FATF's 'Travel Rule' (chunk_ids cf7cefacba3f94bc::383::7d9d, 30a32a386d15ba2b::4f3::edc3). The MAS_TRM passages discuss MAS guidelines for licensees, including the TRM Guidelines and F&P Guidelines, and responses to feedback regarding their application (chunk_ids 20d526d712753652::403::be97, 20d526d712753652::401::f956). The two regimes regulate distinct aspects of the financial services industry: one focuses on AML/CTF obligations and the Travel Rule for digital currency in Australia, while the other focuses on MAS licensing guidelines and principles for financial institutions. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other. Therefore, the regimes are in non_conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.82, "record_type": "conflict", "pair_id": "conflict:f7eb1ca6c03bc015978aad2e", "label": "conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "conflict_type": "structural_unresolved", "severity": "high", "evidence_a": [{"chunk_id": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}], "evidence_b": [{"chunk_id": "cc1be49e9cf8c821::3fc::a271", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "1.1 The Guidelines on Licensing for Digital Token Service Providers (the \"Guidelines\")\nare intended to provide guidance on the application procedures, licensing criteria and\nongoing requirements for Digital Token Service Providers under Part 9 of the Financial\nServices and Markets Act 2022 (the \"FSM Act\"). Under this, digital token service providers are\ndefined as individuals, partnerships or Singapore corporations that are operating from a place\nof business in Singapore or formed or incorporated in Singapore but carry on a business of\nproviding digital token services outside Singapore (\"DTSPs\").\n\n1.2 These Guidelines should be read in conjunction with the provisions of the FSM Act,\nthe Financial Services and Markets (Digital Token Service Provider) Regulations (the \"FSM\nRegulations\") and other relevant legislation, notices, guidelines and FAQs issued by the\nMonetary Authority of Singapore (\"MAS\").\n\n1.3 MAS will update these Guidelines periodically to provide further guidance.\n2. Licence under the FSM Act"}], "rationale": "EU_MICA (broad EU crypto-asset framework, including CASP authorisation) and SG_FSMA_DTSP (Singapore DTSP licensing under FSM Act 2022). Both establish parallel licensing regimes for crypto-asset / digital token services in their respective jurisdictions with no transit pathway. Structural-non-transit conflict.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:55Z", "decision": "accept", "notes": "", "original_conflict_type": "structural_unresolved", "original_severity": "high", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:07:41Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:d946c911e389d2c70916fd18", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "20d526d712753652::3ee::1555", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Harmonizing compliance standards for both financial institutions and payment\nservice providers is the best way to combat the global rise in money laundering,\nterrorism financing, and sanctions evasion, to plug gaps in overseeing transfers of\nvalue. Preventing SG-licensed entities from relying on foreign-licensed institutions 30 May 2025 | 40\nwith only money-transmitter-type licenses would be a useful step towards those\nlarger goals. Question 7. Reliance on Third Party. MAS seeks comments on the proposed amendments to\nthe other AML/CFT notices. No comment. Question 8. Correspondent Account Services. MAS seeks comments on whether the proposed\nrequirements for Correspondent Account Services set out in paragraph 5.6 would\nbe applicable to the sector. (Please refer to paragraph 12 of the draft FSM Notice). For correspondent account services, the licensee is relying on their client's standard\nof compliance in a manner similar to the \"Reliance on Third Party\" issues discussed\nin previous questions."}, {"chunk_id": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "Regime A (INT_BASEL_CRYPTO) regulates capital requirements, risk-weighting, and prudential standards for banks and financial institutions (e.g., exposures to securities firms, collateral treatment). Regime B (SG_MAS_AML_GENERAL) regulates Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) obligations, specifically targeting Digital Payment Token (DPT) providers and financial institutions. The obligations in Regime A relate to financial stability and capital adequacy, while the obligations in Regime B relate to compliance with sanctions, money laundering risks, and licensing requirements. The passages confirm that these regimes govern distinct domains—prudential banking regulation versus AML/CFT compliance—resulting in no overlap of obligations."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:88ff4baf7324976102983cc3", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "a0d157539d5c8040::2fc::beb4", "source_doc": "FinalReport_Market_Abuse_Guidelines_MiCA.pdf", "page": 6, "passage": "2 Background and Legal Basis\nArticle 92 (3) of MiCA:\nIn order to ensure consistency of supervisory practices under this Article, ESMA shall by 30\nJune 2025 issue guidelines in accordance with Article 16 of Regulation (EU) No 1095/2010 on\nsupervisory practices among the competent authorities to prevent and detect market abuse, if\nnot already covered by the regulatory technical standards referred to in paragraph 2.\n\n1. To promote confidence in markets in crypto-assets and ensure their integrity, Title VI of\nMiCA lays down rules on prevention and prohibition of market abuse involving crypto\nassets.\n\n2. Article 92(1) of MiCA requires any PPAET in crypto-assets to have in place effective\narrangements, systems and procedures to prevent and detect market abuse."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "EU_MICA (EU Markets in Crypto-Assets framework — market abuse guidelines under Article 92) and SG_PSA_GENERAL (Singapore Payment Services Act / stablecoin framework). Both regulate crypto/payment services in different jurisdictions. The cited passages address different specific concerns (EU market-abuse supervisory practices vs SG stablecoin regulatory scope). No conflicting obligation on cited passages."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.75, "record_type": "conflict", "pair_id": "conflict:e56d0b5ef82a82a177982b95", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "EU_GDPR (cross-border data transfer / data-processing principles — the cited passage is from the EU's prior TFR predecessor recognising GDPR-style data-protection limits on AML data processing) and SG_AML (MAS Notice 314 AML/CFT training requirements for AML staff, including handling of personal data). When a regulated entity operating across both jurisdictions implements AML training and data-handling per MAS Notice 314 on EU-resident customers, GDPR's cross-border processing restrictions engage. Operationally resolvable via GDPR Art. 6(1)(c) and Chapter V mechanisms.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:47Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T15:25:55Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:0546f992fc55a3bf693eecc8", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::709::b159", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 15, "passage": "2.3 Overview of proposed framework\nLicensing\nThe proposed framework would recognise certain asset holding arrangements as a financial product (a\ndigital asset facility). The existing AFSL framework would apply to any person 'carrying on a financial\nservices business in Australia' in relation to a digital asset facility. Examples of 'financial services'\ninclude:\n• dealing in a financial product (including applying for or acquiring, issuing, varying or disposing of a\nfinancial product)\n• making a market for a financial product\n• providing a custodial or depository service, and\n• providing financial product advice.\nThe issuer of a digital asset facility would be the person or persons responsible for the obligations\nowed to customers under the terms of the asset holding arrangement (platform provider). Platform\nproviders and other intermediaries performing financial services in relation to digital asset facilities\n(e.g. brokers, arrangers, agents, market makers, and advisers) would be required to hold an AFSL.\nWhile the application of the AFSL regime would be jurisdictionally limited to Australia in the usual way,\nan intermediary business in Australia, like a broker, would need to be licensed to provide services that\ninvolve dealing in digital asset facilities generally (including those not licensed or located in Australia).\nSee Part 3 for further detail about licensing obligations.\nFacility contracts\nThe proposed framework would permit digital asset facilities to be paired with other functions,\ncreating digital asset platforms. All arrangements involving digital asset facilities would be required to\nbe structured as non-discretionary arrangements.29 The term 'non-discretionary' means the\narrangements must operate according to pre-agreed and transparent rules and procedures."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "rationale": "The AU_ASIC_AFSL regime regulates the licensing and conduct of financial services providers (specifically digital asset intermediaries) in Australia. The EU_NIS2 regime regulates the security of network and information systems within the European Union. The cited passages confirm that the obligations are jurisdictionally and functionally distinct: Regime A focuses on financial services licensing and conduct (chunk 550958b067dc6726::709::b159), while Regime B focuses on digital operational resilience and security standards (chunk 85307f9e2a040982::14a::134d). There is no specific obligation in one regime that creates a direct, actionable conflict with a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "conflict", "pair_id": "conflict:3fee720bcea67bf3cff5b4d2", "label": "conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AML/CTF Act + Rules"}, "regime_b": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "Privacy Act + APP Guidelines"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "d38ec0ddcc912963::450::6872", "source_doc": "Reporting.pdf", "page": null, "passage": "'@ Australian Government Cee ee\nahem 8 eporting Home / Business / Core guidance / Reporting As a reporting entity you must report certain transactions and suspicious matters, and\nsubmit compliance reports to AUSTRAC. Everyone, including reporting entities, must\nreport cross-border movements of physical currency. Ongoing reporting obligations Threshold transaction reports You must submit threshold transaction reports (TTR) for transfers of A$10,000 or more\nin cash (or the foreign currency equivalent). TTRs are due within 10 business days after\nthe date of the transaction. International funds transfer instruction reports (IFTIs) You must submit international funds transfer instruction reports (IFTIs) for transfers of\nfunds of any value into or out of Australia, made either electronically or under a\ndesignated remittance arrangement. IFTIs are due within 10 business days after the\ntransfer instruction is sent or received. Suspicious matter reports (SMRs) You must submit suspicious matter reports (SMRs) when you have a suspicion that a\ncustomer or transaction is related to criminal activity."}, {"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}, {"chunk_id": "86b8c938e66f203a::281::f792", "source_doc": "AML rules 2007.pdf", "page": 192, "passage": "Exemption of certain types of transactions relating to safe deposit boxes or similar CHAPTER 32\nfacilities\n(e) resort; or\n(f) serviced apartment. Reporting entities should note that in relation to activities they undertake to comply\nwith the AML/CTF Act, they will have obligations under the Privacy Act 1988,\nincluding the requirement to comply with the Australian Privacy Principles, even if\nthey would otherwise be exempt from the Privacy Act. For further information about\nthese obligations, please go to http://www.oaic.gov.au or call 1300 363 992. Anti-Money Laundering and Counter-Terrorism Financing 187\nRules Instrument 2007 (No. 1)"}], "evidence_b": [{"chunk_id": "e9f6b0a9e797777d::634::e686", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Disclosing personal information to an overseas\nrecipient where a permitted general situation\nexists\n8.37 The cross-border principle will not apply if a permitted general situation exists for that\ndisclosure (APP 8.2(d)). Section 16A lists five permitted general situations that may exist for a\ncross border disclosure. These situations are set out below, and are discussed in more detail\nin Chapter C (Permitted general situations) (including the meaning of relevant terms).\n16 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 84. Office of the Australian Information Commissioner - APP Guidelines Page 11 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nLessening or preventing a serious threat to life, health or\nsafety\n8.38 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• it is unreasonable or impracticable to obtain the individual's consent to the disclosure,\nand\n• the entity reasonably believes the disclosure is necessary to lessen or prevent a serious\nthreat to the life, health or safety of any individual, or to public health or safety (s 16A(1),\nItem 1)\n8.39 For example, this permitted general situation might apply where an APP entity discloses the\npersonal information of an individual to a foreign authority, based on a reasonable belief\nthat this disclosure will lessen a serious threat to the health or safety of that individual's\nchildren, but seeking the individual's consent may increase the threat."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}, {"chunk_id": "f9ea5fb6d86aeb75::6f0::32e8", "source_doc": "APP_Guidelines_Consolidated.pdf", "page": 4, "passage": "Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.3, October 2025\n8.27 The mechanism may be a single mechanism or a combination of mechanisms. It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\nException 2 - Disclosing personal information\nto an overseas recipient where the country or a\nbinding scheme is prescribed by regulations\n8.28 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where the overseas recipient of the relevant personal information is:\n• subject to the laws of a country prescribed by regulations, or a participant in a binding\nscheme prescribed by regulations,16 and\n• if the country or binding scheme is prescribed subject to conditions, those conditions are\nsatisfied.17\n8.29 Laws and binding schemes are discussed above at paragraphs 8.22-8.23.\n8.30 The Governor-General may make regulations under the Privacy Act to prescribe these\nmatters.18\nException 3 - Disclosing personal information\nto an overseas recipient with the individual's\nconsent after the individual is expressly\ninformed\n8.31 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))."}], "rationale": "The AML/CTF Act and AML/CTF Rules require reporting entities to collect KYC information, lodge threshold transaction reports and suspicious matter reports, and disclose this personal information to AUSTRAC and (in defined cases) overseas counterparts. The Privacy Act / APPs constrain collection, use and onward disclosure (APP 3, APP 6, APP 8) and place accountability for overseas recipients on the disclosing entity. The AML/CTF Rules themselves explicitly note that reporting entities continue to have Privacy Act obligations in respect of the activities they undertake to comply with the AML/CTF Act, which signals that Parliament intended the regimes to coexist rather than override one another. APP 6.2(b) (use/disclosure required or authorised by Australian law) and the permitted-general-situation doctrine under APP 8.2(d) provide an operative resolution: AML/CTF disclosures are 'authorised by law' and therefore not prevented by APP 6, and overseas-disclosure accountability under APP 8.1 is in practice modulated where the disclosure is to a foreign regulator or FIU under recognised arrangements. The tension is real but routinely managed in practice.", "compliant_paths": ["Use AML/CTF disclosure exceptions: rely on APP 6.2(b) (use or disclosure required or authorised by an Australian law) for AUSTRAC reporting and SMR transmission.", "For overseas disclosure (e.g. to a foreign FIU), document either an APP 8.2(a) reasonable-belief assessment or an APP 8.2(d) permitted general situation per s 16A.", "Maintain an APP 1 transparent privacy policy that explicitly references AML/CTF reporting as a primary purpose of collection."], "out_of_scope_assumptions": ["Reporting entity is registered under the AML/CTF Act and not relying on small-business or media-style Privacy Act exemptions.", "Disclosures are made to AUSTRAC, the ATO, or foreign FIUs under recognised information-sharing arrangements rather than to private parties."]}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:431527d2e02002a9b8319313", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}, {"chunk_id": "85307f9e2a040982::3d7::f935", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 15, "passage": "(68) To evaluate and monitor on a regular basis the ability of an ICT third party service provider to securely provide\nservices to a financial entity without adverse effects on a financial entity's digital operational resilience, several key\ncontractual elements with ICT third-party service providers should be harmonised. Such harmonisation should\ncover minimum areas which are crucial for enabling a full monitoring by the financial entity of the risks that could\nemerge from the ICT third-party service provider, from the perspective of a financial entity's need to secure its\ndigital resilience because it is deeply dependent on the stability, functionality, availability and security of the ICT\nservices received.\n\n(69) When renegotiating contractual arrangements to seek alignment with the requirements of this Regulation, financial\nentities and ICT third-party service providers should ensure the coverage of the key contractual provisions as\nprovided for in this Regulation."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::407::9340", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 86, "passage": "To that end, crypto-asset service providers shall employ appropriate and proportionate\nresources and procedures, including resilient and secure ICT systems as required by Regulation (EU) 2022/2554. Crypto-asset service providers shall establish a business continuity policy, which shall include ICT business continuity\nplans as well as ICT response and recovery plans set up pursuant to Articles 11 and 12 of Regulation (EU) 2022/2554\nthat aim to ensure, in the case of an interruption to their ICT systems and procedures, the preservation of essential data\nand functions and the maintenance of crypto-asset services or, where that is not possible, the timely recovery of such\ndata and functions and the timely resumption of crypto-asset services.\n8. Crypto-asset service providers shall have in place mechanisms, systems and procedures as required by Regulation\n(EU) 2022/2554, as well as effective procedures and arrangements for risk assessment, to comply with the provisions of\nnational law transposing Directive (EU) 2015/849."}, {"chunk_id": "a7dacedbb913f57b::466::c5e8", "source_doc": "FinalReport_MiCA_CP2.pdf", "page": null, "passage": "components of the ICT response and recovery plans of crypto-asset service providers. This Regulation complements those provisions of Regulation (EU) 2022/2554 and of\nDelegated Regulation (EU) xx/xxx on DORA ICT risk management framework] with\nrespect to continuity and regularity in the performance of the crypto-asset services. (3) Certain measures taken by a crypto-asset service provider may not be capable of\nensuring the regularity and continuity of their services when disruptions occur which\nare caused by problems inherent in the operation of the distributed ledger that the\ncrypto-asset service provider does not control, such as permissionless distributed\nledgers. To limit the adverse impact on clients affected by disruptions to services using\na permissionless distributed ledger, the crypto-asset service provider should include\nmeasures for timely communication with clients and other external stakeholders in their\nbusiness continuity plans. Such communication should include essential and timely\ninformation for clients, including ongoing status updates until the incident is resolved\nand services are resumed."}], "rationale": "MiCA Article 68 expressly requires CASPs to employ 'resilient and secure ICT systems as required by Regulation (EU) 2022/2554' (DORA) and to establish ICT business-continuity, response and recovery plans 'pursuant to Articles 11 and 12 of Regulation (EU) 2022/2554'. ESMA's MiCA final report describes its operational-resilience standards as complementing those of DORA. A reasonable single party (a EU-authorised CASP) can — and must — satisfy both regimes simultaneously; no obligation in one points against any obligation in the other. A labeller could mistake this for a conflict because both regimes regulate operational and ICT-related matters for crypto-asset firms, but on inspection MiCA is the sectoral authorisation regime and DORA is the cross-sectoral ICT-risk regime that MiCA explicitly defers to.", "would_conflict_if": ["MiCA later mandated a CASP-specific ICT control that contradicted a DORA standard (current text expressly forecloses this by deferring to DORA)."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:42:45Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:5fcf0c03787fb206f7a1e55e", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "SG_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "5cc4a27bc578287a::165::3333", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 16, "passage": "Article 1\nSubject matter\nThis Regulation establishes a common regulatory framework on insider dealing, the unlawful disclosure of inside\ninformation and market manipulation (market abuse) as well as measures to prevent market abuse to ensure the\nintegrity of financial markets in the Union and to enhance investor protection and confidence in those markets."}, {"chunk_id": "5cc4a27bc578287a::4ee::5950", "source_doc": "MAR_Market_Abuse_Regulation_EU_596-2014.pdf", "page": 33, "passage": "Article 16\nPrevention and detection of market abuse\n1. Market operators and investment firms that operate a trading venue shall establish and maintain effective arrange\nments, systems and procedures aimed at preventing and detecting insider dealing, market manipulation and attempted\ninsider dealing and market manipulation, in accordance with Articles 31 and 54 of Directive 2014/65/EU. A person referred to in the first subparagraph shall report orders and transactions, including any cancellation or\nmodification thereof, that could constitute insider dealing, market manipulation or attempted insider dealing or\nmarket manipulation to the competent authority of the trading venue without delay.\n2. Any person professionally arranging or executing transactions shall establish and maintain effective arrangements,\nsystems and procedures to detect and report suspicious orders and transactions. Where such a person has a reasonable\nsuspicion that an order or transaction in any financial instrument, whether placed or executed on or outside a trading\nvenue, could constitute insider dealing, market manipulation or attempted insider dealing or market manipulation, the\nperson shall notify the competent authority as referred to in paragraph 3 without delay.\n3."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "The EU_MAR regime regulates market abuse, insider dealing, and market manipulation in financial markets (chunk_ids 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The SG_FOUNDATIONAL_LEGISLATION passages discuss the Monetary Authority of Singapore's (MAS) oversight of digital tokens, ICOs, and securities token offerings, as well as international regulatory cooperation (chunk_ids b49627bb889ef1d9::3ef::7168, 7c04f2a0bd85290a::413::fc6a). While both regimes involve financial market integrity, the SG passages focus on the regulation of virtual assets and token offerings, which are distinct from the specific market abuse prohibitions and detection mechanisms detailed in the EU_MAR passages. There is no evidence of a specific obligation in EU_MAR conflicting with a specific obligation in the SG legislation; rather, they operate in different domains regarding the specific instruments and activities regulated."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:10:28Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:6998c58071f8f0c9fe29f085", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}], "evidence_b": [{"chunk_id": "c51ad46265cea4e5::361::e378", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 16, "passage": "57. ESMA is mandated in Article 84(4) of MiCA to develop, in close cooperation with EBA,\ndraft regulatory technical standards (RTS) on the detailed content of the information for\nthe assessment of proposed acquisitions of qualifying holdings in CASPs. The aim of\nthis draft RTS is to specify the detailed content of the information that direct or indirect\nproposed acquirers must provide to national competent authorities (NCAs) when\nnotifying the intended acquisition. This should ensure a harmonised approach to the\nassessment across Member States in the EU of the intended acquisition of qualifying\nholdings in CASPs.\n\n58. The RTSs are applicable to proposed acquirers of qualifying holdings in CASPs, as well\nas NCAs as designated under Article 93(1) of MiCA that will conduct the assessment of\nthe intended acquisition in accordance with Article 83(4) of MiCA."}], "rationale": "The evidence from Regime A (AU_APRA_CPS230) focuses on operational risk management, business continuity, and the resilience of APRA-regulated entities to disruptions (chunk_id f296a7e0bead93df::5e9::d5f4). The evidence from Regime B (EU_MICA_RTS) focuses on the development of regulatory technical standards (RTS) for the assessment of proposed acquisitions of qualifying holdings in Crypto-asset service providers (CASPs) (chunk_id c51ad46265cea4e5::361::e378). The obligations in Regime A relate to internal risk management and resilience, while the obligations in Regime B relate to external notification requirements for acquisitions. These are distinct regulatory domains with no apparent overlap or conflict."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:40:41Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f097bfc741438f237b97ee71", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}], "rationale": "The evidence for Regime A (AU_APRA_CPS234) describes a general prudential practice guide focused on operational risk management and information security for APRA-regulated entities (chunk 4b6fab404e7acfca::3c4::1564). The evidence for Regime B (SG_STABLECOIN) outlines a specific regulatory framework for Single-Currency Stablecoins (SCS) issued in Singapore, distinguishing them from other digital payment tokens (chunk 58f45cd2ef3de201::36c::e2f6). The passages describe distinct regulatory domains—one focused on general prudential risk management for Australian entities and the other on a specific stablecoin issuance regime in Singapore. There is no evidence of a specific obligation in one regime directly conflicting with a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T19:19:09Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:ad7ce0b4b2e761033227fb4b", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "9a96d4d1812f257a::2a6::2422", "source_doc": "161011-APRA-RIS-margining-risk-mitigation-final-assessment-second-pass.pdf", "page": 2, "passage": "2 APRA's prudential framework comprises prudential standards and prudential practice guides (PPGs). APRA is\nempowered to issue legally binding prudential standards that set out specific requirements with which APRA-regulated\ninstitutions - authorised deposit-taking institutions (ADIs), general insurers and life companies (collectively,\ninsurers) and registrable superannuation entity licensees (RSE licensees) - must comply. APRA also issues PPGs,\nwhich clarify APRA's expectations with regard to prudential matters. PPGs frequently discuss legal requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}], "rationale": "The APRA passage describes the Australian prudential regulatory framework, including standards for ADIs and insurers, and the MIFID2 passage describes the European Union's product governance and suitability obligations for investment firms. The obligations in the APRA passage relate to prudential supervision and capital requirements for regulated institutions, while the obligations in the MIFID2 passage relate to the conduct of business, product governance, and suitability assessments for investment services. These are distinct regulatory domains; APRA's prudential standards do not impose the specific product governance and suitability obligations detailed in MIFID2, nor do MIFID2's conduct obligations directly conflict with APRA's prudential capital requirements."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T18:37:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:34976d7ad0f93144d4870083", "label": "non_conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::49a::f39e", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 17, "passage": "12 The AML/CTF regime applies to residents of Australia as well as Australia-based entities or subsidiaries of Australian companies abroad. The\nAML/CTF Act requires reporting entities to identify customers' identities; mandates the collection of certain information for electronic funds\ntransfers; places restrictions on correspondent banking relationships; places certain reporting requirements for suspicious activity, transactions past\na certain threshold and cross-border movement of funds, physical currency and bearer negotiable instruments; and requires the establishment and\ncompliance of an AML and CTF programme that identifies and addresses institutional risk. The AML/CTF Act focuses on regulating businesses that provide a range of services (known as\ndesignated services).13 Businesses that provide designated services are known as reporting entities. Reporting entities must comply with obligations under the AML/CTF legislative regime. There are\ncurrently more than 17,000 reporting entities enrolled with AUSTRAC. All reporting entities must have risk-based systems and controls in their transaction monitoring\nprograms to identify and report suspicious matters."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}], "rationale": "The evidence from Regime A (AU_FEDREG_AML) focuses on obligations for reporting entities regarding customer identification, suspicious transaction reporting, and AML/CTF program compliance (chunk cf7cefacba3f94bc::49a::f39e). The evidence from Regime B (EU_MICA_TITLE_IV_EMT) focuses on the liability of issuers of e-money tokens for information provided in crypto-asset white papers (chunk 491a2f0014d56ffb::702::05e4). The obligations in Regime A relate to anti-money laundering and financial crime prevention, while the obligations in Regime B relate to consumer protection and disclosure requirements for token issuers. The regimes regulate different domains (financial crime compliance vs. product disclosure), and there is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:41:16Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:612a1684eb383bdc33d6ebff", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e3809bb1f352508e::38a::ddd7", "source_doc": "Guidelines_Reverse_Solicitation_MiCA.pdf", "page": 14, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}, {"chunk_id": "25cbbd878a1b21d3::38a::ddd7", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 47, "passage": "Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token issued by an issuer that is not authorised in accordance with\nTitle III of MiCA. At the time of providing the relevant crypto-asset service(s),\nthe third-country firm also markets or offers a widely different type of crypto-\nasset, for instance, meme coins to the EU client. Guideline 4 A third-country firm is contacted by an EU client that wishes to buy an asset-\nreferenced token authorised in the EU under Title III of MiCA. At the time of\nproviding the relevant crypto-asset service(s), the third-country firm also\nmarkets or offers \"meme coins\" to the EU client. Guideline 4 A third-country firm is approached by an EU-based individual for the provision\nof a specific crypto-asset service. In response, the third-country firm offers\nthis individual a package of bundled crypto-asset services."}], "evidence_b": [{"chunk_id": "321e082bdbe732d3::309::b080", "source_doc": "2022_CP_DPT_Services.pdf", "page": 3, "passage": "1.4 Please submit written comments through the link below by 21 December 2022:\nhttps://go.gov.sg/mas-cp-dpt-services-2022\n\n1.5 Should you encounter any technical difficulties in your submission, please send your\nenquiry to capital_markets@mas.gov.sg.\n\n1 These include persons who are currently operating under the transitional exemption as they have been\nproviding DPT services before the commencement of the PS Act and have notified MAS pursuant to the Payment\nServices (Exemption for Specified Period) Regulations 2019. These entities are not licensed under the PS Act but\nare allowed to continue to provide DPT services while their licence applications are being reviewed by MAS.\nMonetary Authority of Singapore 3\n\n2 Introduction\nDigital Asset Ecosystem and Cryptocurrencies"}], "rationale": "The EU_MICA passages describe obligations related to crypto-asset service provision, market abuse prevention, and licensing requirements for crypto-asset service providers (e.g., Guideline 4, Article 92, Article 81). The SG_MAS_AML_GENERAL passages describe the regulatory framework for Digital Payment Token (DPT) services, transitional exemptions, and AML/CFT supervision. The passages do not contain specific obligations in one regime that directly oppose or conflict with obligations in the other. Instead, they address distinct regulatory domains (EU MiCA crypto-asset services vs. Singapore MAS DPT and AML/CFT supervision)."}
+{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.87, "record_type": "non_conflict", "pair_id": "non_conflict:65593afa8c219df54dded621", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + Transfer of Funds Regulation"}, "regime_b": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}, {"chunk_id": "d7502c011527b67c::1a0::faa6", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 24, "passage": "Article 19\nRetention of information on the originator and the beneficiary accompanying the transfer\nIntermediary crypto-asset service providers shall ensure that all the information received on the originator and the\nbeneficiary that accompanies a transfer of crypto-assets is transmitted with the transfer and that records of such\ninformation are retained and made available on request to the competent authorities."}], "evidence_b": [{"chunk_id": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}, {"chunk_id": "85307f9e2a040982::3d7::f935", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 15, "passage": "(68) To evaluate and monitor on a regular basis the ability of an ICT third party service provider to securely provide\nservices to a financial entity without adverse effects on a financial entity's digital operational resilience, several key\ncontractual elements with ICT third-party service providers should be harmonised. Such harmonisation should\ncover minimum areas which are crucial for enabling a full monitoring by the financial entity of the risks that could\nemerge from the ICT third-party service provider, from the perspective of a financial entity's need to secure its\ndigital resilience because it is deeply dependent on the stability, functionality, availability and security of the ICT\nservices received.\n\n(69) When renegotiating contractual arrangements to seek alignment with the requirements of this Regulation, financial\nentities and ICT third-party service providers should ensure the coverage of the key contractual provisions as\nprovided for in this Regulation."}], "rationale": "AMLR/TFR addresses AML/CFT information collection, retention and transmission for transfers of funds and crypto-assets. DORA addresses the ICT-risk management framework, operational resilience, incident reporting and third-party ICT-risk on EU financial entities and CASPs. The two regimes share the same regulated population (PSPs and CASPs in particular) but operate on completely different obligation surfaces. A labeller might wonder whether DORA's record-retention or incident-reporting rules interact with TFR's retention duty (Art. 19) — they do not intersect in content; DORA retention is about ICT logs, TFR is about transaction-level customer data.", "would_conflict_if": ["DORA's data-protection annex provisions (Art. 9(4)(d)) created a stricter retention or pseudonymisation duty inconsistent with TFR's 5-year customer-data retention — they do not."]}
+{"annotator_id": 10116, "annotated_at": "2026-06-15T16:38:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:2b890e07df69d9eb9f8226de", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::4f1::4905", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "Treasury received substantial feedback\nfrom a range of stakeholders with industry-wide support for clarity on the regulatory settings for crypto\nassets. In particular, key stakeholders flagged the need to prioritise the 'token mapping' work, which\ninvolves reviewing a range of crypto assets to identify how they fit within the existing regulatory framework. Accordingly, to commence the reform agenda, I will prioritise the complex 'token mapping' work in 2022. Token mapping is a foundational piece of work to support Government to identify how crypto assets and\nrelated services ought to be regulated. It will also importantly aid the development of a licensing framework\nby assisting in demarcating the perimeter between financial product crypto assets (already the subject of\nfinancial services laws) and non-financial product crypto assets (that may warrant a separate crypto asset\nregulatory framework). Parliament House Canberra ACT 2600 Australia\nOFFICIAL: Sensitive OFFICIAL: Sensitive Subject to your agreement, I propose to announce the reform agenda, commence stakeholder consultations\nand release a public consultation paper on token mapping in 2022 (as indicated in Treasury's earlier\nconsultation paper on crypto licensing and custody requirements)."}, {"chunk_id": "e6bb47e92e88e16c::37a::29f6", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 12, "passage": "16. After token mapping, licensing and custody reforms are the logical next step for crypto reforms\nin Australia. The identification of appropriate obligations and operational standards for crypto\nasset service providers and how they safe-keep assets for customers is a key step for consumer\nprotection; ensuring consumers do not lose assets to avoidable business failure or misuse of\nassets by the provider.\n\n17. The Government will release a consultation paper proposing a licensing and custody framework\nfor crypto asset service providers in mid-2023 to allow for sufficient consultation prior to the\nintroduction of legislation. The paper will reflect ongoing work and consultation in this area and\nleverage the findings from the token mapping exercise. The responses to the following\nquestions will help inform the general direction of future policy and potential consumer\nprotections."}], "evidence_b": [{"chunk_id": "5d489619a0fb9ecf::377::a91e", "source_doc": "Guidance-on-Digital-Identity.pdf.coredownload.pdf", "page": null, "passage": "DIGITAL IDENTITY\nMARCH 2020 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on Digital Identity,\nFATF (2020), FATF, Paris,\nwww.fatf-gafi.org/publications/documents/digital-identity-guidance.html\n© 2020 FATF/OECD."}, {"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "rationale": "The AU_TREASURY_DAP passages describe a domestic policy agenda focused on 'token mapping' and the development of a licensing framework for crypto assets (chunk_ids d75262e404517e0c::4f1::4905, e6bb47e92e88e16c::37a::29f6). In contrast, the FATF_R16 passages provide international guidance on digital identity and anti-money laundering (AML) standards (chunk_ids 5d489619a0fb9ecf::377::a91e, 85240528438654b9::396::417b). The regimes regulate different domains: one is a domestic regulatory reform agenda for crypto assets, while the other is international AML/CFT guidance on digital identity. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
+{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.78, "record_type": "non_conflict", "pair_id": "non_conflict:19e1d6d78f11b5cd5d2a555e", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::413::fc6a", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": null, "passage": "MAS to adopt a collegiate approach with regulators in jurisdiction of issuers and\ndistribution to align enforcements\n6 Binance Question 1. MAS seeks comments on the regulatory scope, particularly on whether the focus on SCS\nis adequate and whether there may be reasons for MAS to extend its regulatory powers\nto SCS issued outside of Singapore. Binance has provided comments to specific questions. More generally, we would observe:\n(a) that MAS may wish to provide recognition for foreign SCS operating in SG that meet\nequivalent regulatory standards in their home jurisdiction. For example, SCS issued under\nEU MiCA regulation, or SCS issued using currencies referred to in paragraph 4.14 of the\nCP. (b) that extending regulatory powers of for example, supervision and enforcement to SCS\nissued outside SG, that operate inside or outside of SG, may be better achieved through\nexisting regulatory cooperation agreements within the financial services sector, including\nthose being developed at the global level by the Financial Stability Board."}], "rationale": "EU_MICA_RTS (EU CASP authorisation technical standards) and SG_PSA_GENERAL (Singapore Payment Services Act general framework). The B passage is actually a MAS consultation response on stablecoin regulation rather than the PSA itself — still SG-side payment-related. Different jurisdictional perimeters and specific obligations; no tension visible."}