{"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:99598e9b5b74da3d816944ba", "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_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "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": "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": "INT_BASEL_GENERAL (Basel III prudential framework) and INT_FATF_GENERAL (FATF AML/CFT standards). Both are international standard-setters; they publish coordinated global financial regulation guidance, addressing prudential and AML concerns respectively but consistently. Aligned pillars of international financial regulation."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:36:17Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:a4caaada5d13046f66d62348", "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_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "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": "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_FEDREG_AML regime regulates Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations for reporting entities, including customer identification, transaction reporting, and suspicious activity reporting (chunk cf7cefacba3f94bc::49a::f39e). The EU_MAR regime regulates Market Abuse (insider dealing, unlawful disclosure of inside information, and market manipulation) to ensure the integrity of financial markets (chunk 5cc4a27bc578287a::165::3333). The obligations and subject matter of the two regimes are distinct; one focuses on financial crime prevention (AML), while the other focuses on market integrity and fair trading practices (Market Abuse). There is no evidence of a specific obligation in A that pushes against a specific obligation in B."}
{"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:9eae9de6e8294f77cc3cdeb2", "label": "conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "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": "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": "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_MICA (EU crypto-asset framework) and SG_PSA_DPT (Singapore PSA DPT-service licensing under MAS PSN02). Parallel jurisdictional licensing regimes for crypto-asset service provision with no transit/recognition pathway. Structural-non-transit conflict.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:57Z", "decision": "accept", "notes": "", "original_conflict_type": "structural_unresolved", "original_severity": "high", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:103a8e35fe718ab3b7f853df", "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": "FATF_R16", "jurisdiction": "International", "issuing_body": "FATF", "short_name": "FATF Recommendation 16 (Travel Rule)"}, "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": "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": "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::4aa::0211", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline (1).pdf", "page": 59, "passage": "181. Countries should ensure that ordering institutions (whether a VASP or other\nobliged entity such as a FI) involved in a VA transfer, obtain and hold required and\naccurate originator information and required beneficiary information and submit\nthe information to beneficiary institutions (whether a VASP or other obliged entity,\nsuch as a FI), if any. Further, countries should ensure that beneficiary institutions\n(whether a VASP or other obliged entity, such as a FI) obtain and hold required (but\nnot necessarily accurate44) originator information and required and accurate\nbeneficiary information, as set forth in INR. 16 (see Box 4 below).\nBox 4. Specific wording definition\nWire transfer rules for VAs/VASPs in INR. 15-7(b)\n\"Recommendation 16\": \"Countries should ensure that originating\nVASPs obtain and hold required and accurate originator information and\nrequired beneficiary information on virtual asset transfers\".\nFootnote: \"As defined in INR. 16, paragraph 6, or the equivalent\ninformation in a virtual asset context.\"\nGlossary of specific terms used in INR. 16\nAccurate: is used to describe information that has been verified for\naccuracy.\nInterpretive Note to Recommendation 16"}], "rationale": "The TFR (Regulation (EU) 2023/1113) is the EU's binding implementation of FATF Recommendation 16 for crypto-asset and fiat wire transfers. FATF guidance paragraphs 178 and 181 specify the originator/beneficiary information that ordering institutions (VASPs or FIs) must obtain, hold and submit; TFR Articles 14–19 transcribe and operationalise that requirement for EU CASPs. A labeller might note that FATF is non-binding 'soft law' while the TFR is binding EU law — but that asymmetry is alignment, not conflict: the binding instrument implements the soft-law standard. This pair is a candidate for the equivalences corpus rather than for conflict at all.", "would_conflict_if": ["FATF revised R.16 in a direction the TFR cannot accommodate without amendment (e.g. dropping the de minimis threshold); even then the conflict would be FATF-vs-TFR-text, not a regulated-entity-level 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:103a8e35fe718ab3b7f853df", "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": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "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": "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": "EU_AMLR_TFR (EU's Regulation 2023/1113 extending AML obligations to CASPs and mandating originator/beneficiary information for crypto transfers) and FATF_R16 (FATF Recommendation 16 — the international travel-rule standard). The EU's TFR is the EU's binding implementation of FATF R16 for crypto-assets; the two reinforce each other directly. Aligned by design."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:49:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:e691754c1e4f8bf98eb225b3", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "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": "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": "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 EU_PSD2 passages regulate the authentication and security of payment services and account information (e.g., strong customer authentication, Article 97; definition of 'personalised security credentials', Article 4). The SG_STABLECOIN passages regulate the issuance and classification of Single Currency Stablecoins (SCS) and the regulatory perimeter for digital payment tokens (DPTs). The obligations in EU_PSD2 relate to the technical security of payment transactions, while the obligations in SG_STABLECOIN relate to the issuance standards and reserve requirements for specific token types. There is no specific obligation in EU_PSD2 that pushes against a specific obligation in SG_STABLECOIN; rather, they govern distinct aspects of the financial ecosystem (payment security vs. token issuance). Therefore, the regimes are in different domains."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T17:04:02Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:c96160be96909e1965685eb1", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_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": "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": "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 Australian Taxation Office (ATO) passage discusses the token mapping of crypto assets and tax compliance, while the Singapore stablecoin passage outlines the MAS regulatory perimeter for Single-Currency Stablecoins (SCS). The ATO passage does not contain specific obligations regarding stablecoin issuance or reserve requirements, nor does it reference Singaporean regulation. Conversely, the Singapore passage focuses on the scope of MAS' stablecoin framework and the regulatory treatment of SCS versus Non-SCS. Since the obligations and regulatory scopes described in the two passages address distinct topics—tax compliance versus financial market regulation—and do not impose conflicting requirements on the same entity or activity, the regimes are in non-conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:49:12Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b2ef03a4261dcf69569fcc74", "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_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "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": "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 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 Singapore Personal Data Protection Act (Regime B) regulates the collection, use, and disclosure of personal data, primarily concerning individual consent and privacy. The specific obligations in the provided passages for Regime A (e.g., preventing disruption to critical operations, managing service provider risks) do not overlap with the specific obligations in Regime B (e.g., obtaining consent for data collection, prohibiting deceptive practices). Therefore, the regimes regulate distinct domains and do not impose conflicting obligations."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:43:42Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:14227e4bed5e59a9d982a4bd", "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_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "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."}, {"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"}, {"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"}, {"chunk_id": "25cbbd878a1b21d3::334::e8c4", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 18, "passage": "4. Adhering to MiCA could pose a significant regulatory challenge for previously\nunregulated crypto firms. Consequently, some might be inclined to continue serving EU\nclients without obtaining authorization as a CASP under MiCA.\n\n5. Whilst Article 61 of MiCA allows unsolicited EU clients to seek third-country firms for the\nprovision of crypto-asset services, such exemption to the authorisation requirements\nunder Article 59 of MiCA must be understood as very narrowly framed and cannot be\nassumed, nor exploited to circumvent MiCA.\n\n6. The guidelines should thus ensure that NCAs, through their supervisory and enforcement\npowers, are able to take all necessary measures to actively protect EU-based investors\nand MiCA-compliant CASPs from undue incursions by non-EU and non-MiCA compliant\nentities.\nPolicy objectives"}], "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 EU MiCA passages (c51ad46265cea4e5::147::6214, c51ad46265cea4e5::2bc::cafa, c51ad46265cea4e5::340::9399, c51ad46265cea4e5::34a::74e3, 25cbbd878a1b21d3::334::e8c4) regulate the licensing and supervision of Crypto-Asset Service Providers (CASPs) and the protection of investors. The SG IRAS passages (abc2247bc6415d1d::5c7::68f5, abc2247bc6415d1d::41e::b184, 7c5602f8b898a7ab::277::e4ae) regulate the Goods and Services Tax (GST) treatment of digital payment tokens. While both regimes address digital assets, they regulate distinct obligations: MiCA focuses on the authorization and conduct of CASPs, whereas IRAS focuses on the tax treatment (exempt status) and record-keeping requirements for token transactions. There is no evidence of a specific obligation in MiCA that conflicts with a specific obligation in IRAS; rather, they operate in different regulatory domains."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:28:02Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:21219c2790e241cb91a4bd17", "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_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "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."}, {"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"}, {"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"}, {"chunk_id": "25cbbd878a1b21d3::334::e8c4", "source_doc": "FinalReport_Reverse_Solicitation_MiCA.pdf", "page": 18, "passage": "4. Adhering to MiCA could pose a significant regulatory challenge for previously\nunregulated crypto firms. Consequently, some might be inclined to continue serving EU\nclients without obtaining authorization as a CASP under MiCA.\n\n5. Whilst Article 61 of MiCA allows unsolicited EU clients to seek third-country firms for the\nprovision of crypto-asset services, such exemption to the authorisation requirements\nunder Article 59 of MiCA must be understood as very narrowly framed and cannot be\nassumed, nor exploited to circumvent MiCA.\n\n6. The guidelines should thus ensure that NCAs, through their supervisory and enforcement\npowers, are able to take all necessary measures to actively protect EU-based investors\nand MiCA-compliant CASPs from undue incursions by non-EU and non-MiCA compliant\nentities.\nPolicy objectives"}], "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": "3d521e61e49aaf46::df::cfe0", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": null, "passage": "MAS Notice 314\n28 June 2021\nNOTICE TO DIRECT LIFE INSURERS\nMONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186\nNOTICE ON PREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING\nOF TERRORISM - DIRECT LIFE INSURERS\nINTRODUCTION"}, {"chunk_id": "6d8a84a9f3d6e9e4::b0::8350", "source_doc": "Guidelines_to_MAS_Notice_SFA04-N02_2025.pdf", "page": null, "passage": "Monetary Authority of Singapore\nP9\nGUIDELINES TO\nMAS NOTICE SFA04-N02\nON PREVENTION OF\nMONEY LAUNDERING\nAND COUNTERING THE\nFINANCING OF\nTERRORISM\n1July 20 25\n\nTABLE OF CONTENTS"}, {"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."}, {"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 MiCA passages (c51ad46265cea4e5::147::6214, c51ad46265cea4e5::2bc::cafa, c51ad46265cea4e5::340::9399, c51ad46265cea4e5::34a::74e3, 25cbbd878a1b21d3::334::e8c4) focus exclusively on the licensing, authorisation, and registration requirements for Crypto-Asset Service Providers (CASPs) under the Markets in Crypto-Assets Regulation. In contrast, the Singapore AML passages (3d521e61e49aaf46::38f::e615, 3d521e61e49aaf46::df::cfe0, 6d8a84a9f3d6e9e4::b0::8350, 018117ef1e757630::428::d321, 39886a6842407c92::356::ee53) address general AML/CFT obligations, training, and customer due diligence applicable to financial institutions and banks. The obligations in MiCA regarding the application for authorisation and the establishment of a public register (c51ad46265cea4e5::147::6214, c51ad46265cea4e5::34a::74e3) do not impose conflicting requirements with the general AML/CFT supervisory expectations outlined in the Singapore passages (3d521e61e49aaf46::38f::e615, 39886a6842407c92::356::ee53). The regimes regulate distinct aspects of the financial ecosystem—MiCA focuses on the entry and operation of crypto-asset service providers, while the Singapore regime focuses on the broader AML/CFT compliance framework for financial institutions."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:53:28Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:82ac2325d144985a37557029", "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_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_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": "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 for AU_TRAVEL_RULE indicates that Australia is currently consulting on extending the FATF 'Travel Rule' to digital currency transactions, but notes that the rule has not yet been implemented for digital currency exchanges (chunk_ids cf7cefacba3f94bc::383::7d9d, 30a32a386d15ba2b::4f3::edc3). The evidence for SG_MAS_AML_GENERAL confirms that entities providing Digital Payment Token (DPT) services are subject to MAS licensing and AML/CFT obligations (chunk_id 321e082bdbe732d3::309::b080). The regimes are not in conflict because the AU_TRAVEL_RULE passage describes a proposed future regulatory change that has not yet taken effect, whereas SG_MAS_AML_GENERAL outlines the current regulatory framework. The 'Travel Rule' is a topic of consultation in Australia, not an active, conflicting obligation."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:48:42Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:8c10cce99cd321dbca6a7f6d", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "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": "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": "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 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 for the EU GDPR (Regime B) concerns the legal basis for processing personal data and the conditions for lawful processing (chunk bd84e63f5b622b73::6a8::d132). The obligations in the Australian Corporations Act do not impose data protection requirements that conflict with the EU GDPR's principles of lawful processing, purpose limitation, or data subject rights. The regimes regulate distinct aspects of corporate governance and data protection, respectively, 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": "2026-06-15T16:37:02Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:dc073484c86a2f5bc2160503", "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_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_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": "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 regimes regulate distinct aspects of the crypto ecosystem. Regime A (AU_ATO_CRYPTO) focuses on tax compliance and the token mapping of crypto assets for Australian tax purposes (chunk_id e6bb47e92e88e16c::567::36c4). Regime B (SG_MAS_PRUDENTIAL_CRYPTO) focuses on prudential standards, capital requirements, and the regulation of stablecoin issuers and payment services in Singapore (chunk_id 7c04f2a0bd85290a::449::02f2). The obligations in Regime A relate to tax reporting, while the obligations in Regime B relate to financial stability and capital adequacy. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B; rather, they operate in different domains (taxation vs. prudential regulation)."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:46:40Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:d7b6b866cb0a719b1ecbf2b8", "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_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_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": "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."}], "rationale": "The EU regime regulates the solicitation of clients by third-country crypto-asset service providers (reverse solicitation rules under MiCA). The SG regime passages discuss general AML/CFT compliance, reliance on third parties, and sanctions regulations. There is no evidence in the SG passages that mandates or prohibits the solicitation of clients by third-country firms, nor does it impose specific obligations on the initiation of crypto-asset services that conflict with the EU's reverse solicitation exemption. The SG passages focus on general compliance standards and risk management rather than the specific operational mechanics of client initiation. Therefore, the regimes regulate different domains regarding this specific interaction."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.75, "record_type": "conflict", "pair_id": "conflict:2f473162367fe72df44179b9", "label": "conflict", "regime_a": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "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": "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": "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_GENERAL (FATF general AML/CFT standards) and SG_PDPA (Singapore Personal Data Protection Act). When SG implements FATF AML standards through MAS notices, the resulting customer-data collection and sharing engages PDPA restrictions. Operationally resolvable via PDPA s.13(b) ('required or authorised by law'). Low severity because FATF general is broader than R16/travel-rule specifically.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:05Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "low", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:20:06Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f617f7be1665c482ef233bf7", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "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": "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": "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 evidence for Regime A (AU_APRA_CPS234) describes a Prudential Practice Guide regarding Operational Risk Management and Information Security, which applies to APRA-regulated entities. The evidence for Regime B (EU_AMLR_TFR) describes the scope of EU AML/CFT regulations regarding information accompanying transfers of funds and crypto-assets. The obligations in Regime A relate to internal risk management frameworks and resilience, while the obligations in Regime B relate to external reporting and anti-money laundering compliance for cross-border transfers. The regimes regulate distinct domains (internal prudential risk vs. external financial crime reporting) and do not impose conflicting obligations on the same specific activity."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:40:06Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:c9d544e11f322a18c8efa65b", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "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": "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": "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_MAR regime regulates market abuse, insider dealing, and market manipulation (chunks 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The SG_MAS_AML_GENERAL regime regulates Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) compliance, targeted financial sanctions, and cybersecurity issues (chunks 6d8a84a9f3d6e9e4::480::ac46, b49627bb889ef1d9::1b6::0802). The obligations in the EU_MAR passage relate to the prevention and detection of market manipulation and insider dealing, while the obligations in the SG_MAS_AML_GENERAL passage relate to AML/CFT supervision, sanctions, and cybersecurity. These are distinct regulatory domains with no apparent overlap of obligations. 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:c7d75e91dacd2bb40323b410", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU Treasury DAP"}, "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": "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."}], "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): AU Treasury Digital Asset Platforms framework and AUSTRAC TTR $10k cash threshold reporting operate in disjoint regulatory domains at the obligation level. Proposed DAP framework 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": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:5841ce45ea35ab4dbdfa6b2f", "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_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "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": "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": "AU_TTR_THRESHOLD (AUSTRAC threshold-transaction reports — AUD 10,000+ cash transactions) and SG_MAS_AML_GENERAL (MAS AML/CFT framework for DPT providers, including risk-based supervision). Both are AML/CFT frameworks in their respective jurisdictions consistent with FATF standards; entities operating across both face complementary AML duties. Reinforcing relationship."}
{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:3ff79c22f9a69249a0350481", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 234 Information Security"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "FATF", "short_name": "FATF Recommendation 16 (Travel Rule)"}, "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": "85240528438654b9::4aa::0211", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline (1).pdf", "page": 59, "passage": "181. Countries should ensure that ordering institutions (whether a VASP or other\nobliged entity such as a FI) involved in a VA transfer, obtain and hold required and\naccurate originator information and required beneficiary information and submit\nthe information to beneficiary institutions (whether a VASP or other obliged entity,\nsuch as a FI), if any. Further, countries should ensure that beneficiary institutions\n(whether a VASP or other obliged entity, such as a FI) obtain and hold required (but\nnot necessarily accurate44) originator information and required and accurate\nbeneficiary information, as set forth in INR. 16 (see Box 4 below).\nBox 4. Specific wording definition\nWire transfer rules for VAs/VASPs in INR. 15-7(b)\n\"Recommendation 16\": \"Countries should ensure that originating\nVASPs obtain and hold required and accurate originator information and\nrequired beneficiary information on virtual asset transfers\".\nFootnote: \"As defined in INR. 16, paragraph 6, or the equivalent\ninformation in a virtual asset context.\"\nGlossary of specific terms used in INR. 16\nAccurate: is used to describe information that has been verified for\naccuracy.\nInterpretive Note to Recommendation 16"}], "rationale": "CPS 234 governs ICT/information-security capability of APRA-regulated entities; FATF Recommendation 16 governs originator/beneficiary information for VA and wire transfers under AML/CFT. Completely different obligation surfaces. This is a textbook easy negative for the conflict-detector training set.", "would_conflict_if": ["An APRA-regulated VASP claimed CPS 234's information-security duty prevented it from sharing originator data with a beneficiary VASP — but APP 11 / CPS 234 'security' is about protecting data in transit, not about refusing to send it; the requirements coexist."]}
{"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:2a16226a46a5b801aa37b235", "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_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "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::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": "AU_ASIC_CRYPTO (ASIC's INFO 225 / financial-product classification framework for digital assets in Australia) and EU_MICA_TITLE_V_CASP (EU CASP authorisation requirements under MiCA Article 62). Both regulate crypto-asset service providers but apply in different jurisdictions with materially different mechanisms — AU classifies by financial-product status, EU has a dedicated CASP regime. The cited passages don't impose conflicting obligations on the same entity action."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:34:05Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:60d966bc4b14c057706f6ef3", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "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": "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": "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 Regime A (AU_PRIVACY) relate to the cross-border disclosure of personal information and the accountability of an entity for overseas recipients. The obligations in Regime B (INT_BASEL_CRYPTO) relate to the capital requirements, risk weighting, and supervisory standards for bank exposures and financial institutions. The specific obligations in the passages do not overlap; one governs data privacy and cross-border data flows, while the other governs banking sector capital adequacy and prudential supervision. Therefore, the regimes regulate different domains and do not conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:34:47Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:e455214932cae652357fc540", "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_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "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::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 DORA passages focus on digital operational resilience, ICT risk management, and contractual arrangements with third-party service providers (e.g., 'digital operational resilience', 'ICT third-party service provider', 'ICT risk management requirements') [85307f9e2a040982::3d7::f935, 85307f9e2a040982::5f2::974e]. The INT_BASEL_GENERAL passages focus on capital adequacy, leverage ratios, and the treatment of provisions and expected losses (e.g., 'leverage ratio exposure measure', 'general provisions/general loan-loss reserves', 'expected loss') [32afd37cade34f84::34b::8d30, 32afd37cade34f84::25d::6825]. The obligations and subject matter of the two regimes are distinct; there is no specific obligation in DORA that pushes against a specific obligation in Basel III regarding capital or leverage. Therefore, the regimes do not conflict."}
{"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:9bada48c6c2469fedcdf80a5", "label": "conflict", "regime_a": {"regime_id": "SG_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "IRAS", "short_name": "SG_IRAS_TAX"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "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": "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": "3d521e61e49aaf46::df::cfe0", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": null, "passage": "MAS Notice 314\n28 June 2021\nNOTICE TO DIRECT LIFE INSURERS\nMONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186\nNOTICE ON PREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING\nOF TERRORISM - DIRECT LIFE INSURERS\nINTRODUCTION"}], "rationale": "SG_IRAS_TAX (IRAS Singapore tax framework — including DPT GST exemption from 2020 plus income-tax / capital-gains recordkeeping requirements for crypto-asset disposals) and SG_AML (MAS Notice 314 and related AML notices — training, CDD, and suspicious-matter reporting). Same recurring friction as AU_ATO :: AU_AML in the AU framing: every transaction generates parallel IRAS recordkeeping and MAS AML obligations. Severity low because GST exemption for DPTs reduces some of the IRAS-side burden.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:50Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "low", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:06:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:2d77f9d95b128a7e158bb28a", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "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": "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 APRA (Regime A) focuses on the Australian prudential framework, specifically the issuance of legally binding prudential standards and practice guides for ADIs, insurers, and RSE licensees (chunk 9a96d4d1812f257a::2a6::2422). The evidence for EU_EMD2 (Regime B) refers to a Directive (EU) 2022/2556 regarding digital operational resilience for the financial sector (chunk 85307f9e2a040982::14a::134d). The passages describe distinct regulatory frameworks governing different jurisdictions (Australia vs. the EU) and different regulatory objectives (prudential standards vs. digital operational resilience). 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": "2026-06-15T19:29:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:56710c8a8e717fb9b3b7aa03", "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_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "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": "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_TTR_THRESHOLD regime regulates the reporting of physical cash transactions exceeding A$10,000 to AUSTRAC (chunk_ids 6dfe4e63b9fb3c74::3bc::1a3f and 254ca2d92d196180::377::d0c6). The EU_MAR regime regulates market abuse, insider dealing, and market manipulation in financial markets (chunk_id 5cc4a27bc578287a::165::3333). The obligations in the EU_MAR passages relate to the prevention and detection of market abuse by market operators and investment firms, not to the reporting of physical cash thresholds. Therefore, the regimes regulate distinct 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:313e24d460f6c6cf9ec62ef4", "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_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "conflict_type": "structural_unresolved", "severity": "high", "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": "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": "EU_MICA_TITLE_V_CASP (EU CASP authorisation framework under MiCA Article 62) and SG_PSA_DPT (Singapore PSA DPT service licensing). Both establish parallel crypto-asset service provider licensing frameworks in different jurisdictions, with no transit pathway between them. An EU-authorised CASP cannot operate as an SG DPT licensee without separate SG authorisation; the converse also holds. Same structural-non-transit shape as AU_DAP ↔ EU_MICA (careful cohort label).", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:52Z", "decision": "accept", "notes": "", "original_conflict_type": "structural_unresolved", "original_severity": "high", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:45:31Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:c467869058b6d3b468060002", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "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": "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": "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": "The EU DAC8 regime regulates the automatic exchange of tax information regarding crypto-asset users (chunk_ids c0300673081f7232::320::7b46, c0300673081f7232::498::163c). The SG AML regime regulates the prevention of money laundering and terrorism financing, including customer due diligence and reporting obligations for financial institutions and digital payment token service providers (chunk_ids 3d521e61e49aaf46::38f::e615, 018117ef1e757630::428::d321). The obligations in DAC8 relate to tax transparency and administrative cooperation, while the obligations in SG AML relate to financial crime prevention and internal controls. These are distinct regulatory domains that do not impose conflicting obligations on the same activity; rather, they operate in parallel to address different risks (tax evasion vs. money laundering)."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:34:05Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:1a941b6a7e1b1efee40dd37a", "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_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_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": "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 DAC8 regime regulates tax transparency and the reporting of crypto-asset user information to tax authorities (c0300673081f7232::320::7b46, c0300673081f7232::498::163c). In contrast, the INT_BASEL_GENERAL regime addresses banking supervision, capital adequacy, and leverage ratios (32afd37cade34f84::34b::8d30, ffa7a3de1e0fc7f0::7bc::38ba). The obligations in DAC8 relate to administrative cooperation and tax reporting, while the obligations in INT_BASEL_GENERAL relate to financial institution capital and risk management. 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": "2026-06-15T15:18:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:f883e5b04671d53c4ba21b59", "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_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "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::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": "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": "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 VASP regime focuses on AML/CFT obligations and definitions for Virtual Asset Service Providers (chunk 85240528438654b9::1cd::07d7, chunk 85240528438654b9::3c5::d461). The Singapore MAS Prudential Crypto regime focuses on capital adequacy, risk management, and licensing for Digital Payment Token (DPT) services and Stablecoin issuers (chunk 321e082bdbe732d3::309::b080, chunk 7c04f2a0bd85290a::449::02f2). While both regulate crypto assets, they operate in different domains: FATF establishes minimum standards for AML/CFT, whereas MAS establishes prudential standards for financial stability and consumer protection. The passages do not show a specific obligation in one regime pushing against a specific obligation in the other; rather, they reinforce the need for a robust regulatory framework in different areas. Therefore, the regimes are non-conflicting."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:27:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:349888d58e6dd39dbaf3aeda", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "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": "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": "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_MIFID2 passages describe obligations for investment firms regarding product governance, suitability assessments, and client information disclosure (e.g., Article 1, Article 24, Article 25). The SG_PSA_GENERAL passages discuss the scope of the Payment Services Act, specifically regarding digital payment token services, licensing, and transitional exemptions (e.g., section 23(14), transitional entities). The obligations in MIFID2 relate to the conduct of investment services and product manufacturing, while the obligations in the SG_PSA_GENERAL relate to payment services licensing and asset safeguarding. The regimes regulate distinct domains of financial services activity, 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": "2026-06-15T16:33:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:6fff6b6d5a75fc6e031f7bcd", "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_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "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": "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_TREASURY_DAP passages discuss the Australian government's 'token mapping' exercise and the development of a licensing framework for crypto assets to clarify regulatory application (chunk_id d75262e404517e0c::47b::7c9f). The SG_AML passages focus on the Monetary Authority of Singapore's (MAS) AML/CFT supervisory expectations for Digital Payment Token (DPT) service providers, specifically regarding risk awareness and controls (chunk_id 018117ef1e757630::428::d321). The regimes regulate different aspects of the crypto ecosystem: one focuses on the overarching regulatory perimeter and licensing framework for crypto assets in Australia, while the other focuses on specific AML/CFT controls for DPT service providers in Singapore. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:061969805f6a526ad94a7bb8", "label": "non_conflict", "regime_a": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"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______________________________________________________________________"}], "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": "SG_PSA_DPT (MAS Notice PSN02 — AML/CFT obligations for DPT-licence holders under the Payment Services Act) and SG_PSA_GENERAL (broader Singapore Payment Services Act framework and amendments). The DPT framework is a subset of the general PSA framework; they operate together. The cited passages confirm PSN02 is issued under the PSA framework, with the general PS Regulations providing the supporting structure."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:35:48Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:30ae9ad008fdc39373882277", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "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": "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": "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 evidence for APRA CPS234 (chunk 4b6fab404e7acfca::3c4::1564) describes the publication as a 'Prudential practice guide' that discusses requirements from legislation but does not create enforceable requirements. The evidence for MIFID II (chunk 28dfda0f6a6539b6::620::92ed) outlines obligations for investment firms regarding product approval processes and information disclosure. The obligations in MIFID II relate to investment services and product governance, while the APRA passage describes the nature of the APRA guidance document itself. There is no specific obligation in APRA CPS234 that pushes against a specific obligation in MIFID II; the regimes regulate different domains (Australian prudential guidance vs. EU investment services regulation)."}
{"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:6c9c6809ff5c48a40e2a50c5", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 230"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "SG PSA DPT"}, "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": "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."}, {"chunk_id": "39886a6842407c92::7cf::c2ec", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 2, "passage": "2 In the case of a limited liability partnership or a limited partnership. Securities Regulation issued by the International Organisation of Securities\nCommissions, or the Insurance Core Principles issued by the International Association of\nInsurance Supervisors;\n\"cross-border wire transfer\" means a wire transfer where the ordering institution and the\nbeneficiary institution are located in different countries or jurisdictions and also refers to\nany chain of wire transfer in which at least one of the financial institutions involved is\nlocated in a different country or jurisdiction;\n\"custodian wallet service\" means the service of safekeeping and administration of digital\npayment tokens or instruments enabling control over digital payment tokens;\n\"customer\", in relation to a bank, means a person (whether a natural person, legal person\nor legal arrangement) -\n(a) with whom business relations are established or with whom the bank intends to\nestablish business relations; or\n(b) for whom the bank undertakes or intends to undertake any transaction without an\naccount being opened;\n[MAS Notice 626 (Amendment) 2025]\n\"digital CMP token\" means a digital representation of a capital markets product which can\nbe transferred, stored or traded electronically;\n\"digital payment token\" has the same meaning as defined in section 2(1) of the PS Act;\n\"digital payment token service\" has the same meaning as defined in section 2(1) of the\nPS Act;\n\"digital payment token transfer service\" means the service of accepting digital payment\ntoken from one digital payment token address or account, whether in Singapore or outside\nSingapore, as principal or agent, for the purposes of transferring, or arranging for the\ntransfer of, the digital payment token to another digital payment token address or account,\nwhether in Singapore or outside Singapore;\n\"digital token\" means -\n(a) a digital payment token; or\n(b) a digital CMP token;\n\"digital token transaction\" means -\n(a) a payment service transaction; or"}], "rationale": "APRA CPS 230 is an Australian operational-risk standard for APRA-regulated entities; the SG PSA DPT regime governs Singapore digital-payment-token service providers. Different jurisdictions, different regulated populations, different subject matters. Easy hard negative.", "would_conflict_if": ["A firm dual-regulated as both APRA-RE and SG DPT licensee — the regimes apply cumulatively on their respective jurisdictional surfaces."]}
{"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:831903d1b52ae4d9933c37e1", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "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": "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": "FATF_R16 (FATF Recommendation 16 — AML travel rule for VAs/VASPs) and INT_BASEL_CRYPTO (Basel prudential treatment of crypto-asset exposures for banks). Both are international standards bodies addressing crypto-asset regulation from different but coordinated angles (AML and prudential). Aligned pillars of international financial regulation."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:41:03Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f6a790e1bc5f43d28d59d313", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "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": "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_PRIVACY regime regulates the cross-border disclosure of personal information, requiring entities 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 MAS_TRM regime regulates the conduct of financial institutions and licensees, focusing on principles-based guidelines for risk assessments and business practices (chunk_id 20d526d712753652::401::f956). The obligations in AU_PRIVACY relate to data protection and cross-border data flows, while the obligations in MAS_TRM relate to financial institution conduct and risk management. There is no specific obligation in MAS_TRM that directly conflicts with the requirement to ensure overseas recipients comply with APPs. Therefore, the regimes are in different domains and do not conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:48:52Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:54f9e1eca33145c6c213f624", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "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": "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_EMD2 passages focus on digital operational resilience for the financial sector, specifically Directive (EU) 2022/2556 and Regulation (EU) 2022/2554 (chunks 85307f9e2a040982::14a::134d and cf4bab4773787409::1e6::5413). In contrast, the FATF_R16 passages address Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) standards, including guidance on digital identity and virtual assets (chunks 5d489619a0fb9ecf::377::a91e and 85240528438654b9::396::417b). The obligations in the EU regime regarding operational resilience do not conflict with the AML/CFT obligations in the FATF regime; rather, they regulate distinct domains of financial stability and compliance."}
{"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:50eab80c91647718f8aa4d03", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "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": "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."}, {"chunk_id": "3a1785f95cb37b3c::4d8::cae3", "source_doc": "AMLA_Regulation_EU_2024-1620.pdf", "page": 33, "passage": "Article 14\nAdditional transfer of direct supervision tasks and powers in exceptional circumstances upon the request of\na financial supervisor\n1. A financial supervisor may submit a reasoned request to the Authority for the Authority to assume direct supervision\nand carry out the tasks listed in Article 5(2) with respect to a particular non-selected obliged entity. The request referred to in the first subparagraph shall only be submitted in exceptional circumstances with the aim of\naddressing at Union level a heightened ML/TF risk or compliance failures at a non-selected obliged entity and to ensure\na consistent application of high supervisory standards.\n2. The request referred to in paragraph 1 shall:\n(a) identify the non-selected obliged entity in respect of which the financial supervisor is of the view that the Authority\nshould assume direct supervision;\n(b) state the reasons for which AML/CFT direct supervision of the non-selected obliged entity is necessary;\n(c) identify and duly justify the proposed transfer date and the period for which the transfer of the tasks and powers is\nrequested; and\n(d) provide all necessary supporting information, data and evidence that could be useful for the assessment of the request.\n3."}], "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": "AMLA (Regulation (EU) 2024/1620) establishes the EU Anti-Money Laundering Authority — the supervisor for selected obliged entities subject to AMLR (Regulation (EU) 2024/1624) and the TFR. The two regulations are part of the same AML/CFT package and are structurally complementary: AMLR imposes substantive obligations on obliged entities, AMLA supervises those entities directly under Articles 13–14. No obligation in AMLA points against any obligation in AMLR; AMLA's authority is *to enforce* AMLR. Easy hard negative.", "would_conflict_if": ["AMLA exercised supervisory powers beyond AMLR's substantive scope — Art 13 cabins AMLA's direct-supervision perimeter."]}
{"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:63a8c5f5026641fdab792306", "label": "conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "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::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": "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_DAC8 (EU directive on administrative cooperation for crypto-asset reporting — Articles 19+ requiring crypto-asset operators to report personal data of crypto-asset users including those resident in non-Union jurisdictions when qualifying competent authority agreements exist) and SG_PDPA (Singapore Personal Data Protection Act — consent/disclosure restrictions). DAC8's cross-jurisdictional reporting of SG-resident crypto-asset users' personal data to EU tax authorities engages PDPA on the SG side. Operationally resolvable via PDPA s.13(b) ('required or authorised under any other written law') plus inter-jurisdictional competent-authority agreements. Same shape as the AML reporting × privacy conflict family, applied to tax-reporting context.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:20Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:08:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:18272c7cb8ec5f1bf1fcc323", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "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": "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": "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_MAR regime regulates market abuse, specifically insider dealing and market manipulation (chunk 5cc4a27bc578287a::4ee::5950). 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 cc1be49e9cf8c821::2f4::ea8f). The obligations in MAR relate to the prevention and detection of market abuse by market operators and investment firms, whereas the obligations in SG_FSMA_DTSP relate to the licensing requirements and operational conduct of DTSPs. The passages describe distinct regulatory domains with no apparent overlap of specific obligations that would create a conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:54:09Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:381f70f94f29e4b1897f5149", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "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": "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": "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 AMLA regime focuses on the institutional framework for anti-money laundering and countering the financing of terrorism (AML/CFT), including the establishment of the Authority for AMLA and cooperation with supervisory authorities (chunk df546f2364aaf9e2::25a::6ab3). The Singapore Stablecoin regime focuses on the regulatory perimeter for Single-Currency Stablecoins (SCS) issued in Singapore, distinguishing them from other digital payment tokens (chunk 58f45cd2ef3de201::36c::e2f6). The obligations in the EU regime relate to information exchange and supervisory cooperation, while the Singapore regime relates to the scope of stablecoins and reserve asset requirements. These are distinct regulatory domains with no apparent overlap of obligations."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:55:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:5284ab1584d82fea5bd72aee", "label": "non_conflict", "regime_a": {"regime_id": "AU_PAYMENT_SYSTEMS", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_PAYMENT_SYSTEMS"}, "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": "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."}], "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 AU_PAYMENT_SYSTEMS passage discusses the powers of the Authority to ensure interoperability between payment systems and the requirements for payment service providers to access technical infrastructures (chunk_id 6644db515eb0e280::423::b3f1). The SG_STABLECOIN passage outlines the scope of MAS's stablecoin framework, specifically distinguishing between Single-currency Stablecoins (SCS) and Non-SCS, and clarifying that Non-SCS will continue to be subject to the existing DPT regulatory regime (chunk_id 58f45cd2ef3de201::36c::e2f6). The obligations in the Australian regime regarding payment system interoperability and access do not overlap with the Singaporean regime's classification of stablecoin types. Therefore, the regimes are in different domains and do not conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T05:19:24Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:8fa19ab567907c78eed5d5bd", "label": "conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "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::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": "AU_PRIVACY (APP 8 cross-border disclosure of personal information) and EU_DAC8 (EU directive on administrative cooperation for crypto-asset reporting — mandates cross-jurisdictional reporting of crypto-asset users' personal data, including those resident in non-Union jurisdictions like Australia, to EU tax authorities). When EU CASPs hold data on AU-resident crypto-asset users and transmit it to EU tax authorities under DAC8 reporting requirements, APP 8 engages on the AU side (AU APP entities have obligations regarding 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 framework, supported by AU-EU tax-information-exchange agreements. Same shape as DAC8 × PDPA conflict, applied to AU-EU cross-jurisdictional framing. Severity medium because DAC8's structured reporting is sharper than ad-hoc tax reporting.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:47Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:20:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:1922f213d7f20a1570c7e02f", "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_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_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::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": "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 MiCA passages focus on the requirements for obtaining authorisation as a Crypto-Asset Service Provider (CASP), including the information to be submitted to the National Competent Authority (NCA) and the establishment of a public register (c51ad46265cea4e5::147::6214, c51ad46265cea4e5::340::9399). In contrast, the Singapore MAS passages discuss Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) obligations, specifically regarding the FSM Sanctions Regulations, reliance on third parties, and the risk-based supervision of Digital Payment Token (DPT) providers (20d526d712753652::3ee::1555, b49627bb889ef1d9::1b6::0802). While both regimes regulate crypto-asset service providers, the obligations cited relate to distinct regulatory pillars: MiCA focuses on the licensing and registration process, whereas MAS focuses on AML/CFT compliance and sanctions. There is no evidence in the provided passages of a specific obligation in MiCA that directly conflicts with a specific obligation in the MAS AML/CFT regime."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:36:44Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:e9851b029ec2ea0ba1d0c3a1", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_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": "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."}], "rationale": "The AU_ASIC_AFSL regime regulates the licensing and conduct of financial services providers (e.g., platform providers, brokers) dealing in digital asset facilities. The AU_ATO_CRYPTO regime, based on the provided passages, focuses on the tax treatment and compliance approach for crypto assets, including token mapping and tax return reporting. The obligations in Regime A (licensing, financial requirements, conduct) do not directly oppose the obligations in Regime B (tax reporting, compliance approach). The regimes regulate different domains—financial services conduct versus tax administration—resulting in no conflict."}
{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:81f573b722d813d60d2d5e1c", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU Privacy"}, "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": "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": "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"}], "rationale": "The Privacy Act / APPs regulate handling of personal information generally. The TTR regime regulates threshold transaction reports for cash transactions of A$10,000 or more. The two regimes apply to overlapping populations (AUSTRAC-registered reporting entities are also APP entities) but the subject matters are essentially disjoint: TTR is a reporting duty, not a personal-data-handling rule. APP 6.2(b) provides the law-required carve-out for any personal-data leg of the TTR submission. Hard negative.", "would_conflict_if": ["TTR Form fields demanded personal information beyond what APP 3 collection-purpose would allow — current TTR fields stay within reasonable AML/CTF collection necessity."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:21:58Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:3ab4e566211ee24bab6fdd6e", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "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": "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": "The EU_MAR passages regulate financial market integrity, specifically insider dealing and market manipulation (chunks 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The SG_PDPA passages regulate the collection, use, and disclosure of personal data, focusing on consent requirements and data protection (chunks 0e996ae99839f19e::37b::85a8, 0e996ae99839f19e::61d::14e5). The obligations in the EU_MAR relate to preventing market abuse and detecting insider dealing, while the obligations in the SG_PDPA relate to obtaining consent for personal data processing. These are distinct regulatory domains with no apparent overlap of obligations or conflicting requirements."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:50:19Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:91b35ac9d7e525850692a699", "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_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "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": "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_TREASURY_DAP passages discuss the Australian government's 'token mapping' exercise and the development of a licensing framework for crypto assets (chunk_ids: d75262e404517e0c::47b::7c9f, e6bb47e92e88e16c::37a::29f6). In contrast, the EU_PSD2 passages regulate payment services, specifically focusing on strong customer authentication and the authorisation of payment institutions (chunk_ids: adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b). The obligations in the EU regime relate to electronic payment transactions and authentication, whereas the Australian regime addresses the broader regulatory perimeter of crypto assets and the licensing of crypto asset service providers. The two regimes regulate distinct domains—payment services versus crypto asset regulation—and do not impose conflicting obligations on the same entity or transaction type."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:58:45Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:6ad88c7390cdd94146f38376", "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_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_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": "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_REVERSE_SOLICITATION regime regulates the authorization and solicitation of crypto-asset services for third-country firms serving EU clients (chunk_id 25cbbd878a1b21d3::4f8::561c). In contrast, the INT_IOSCO_GENERAL regime provides a general methodology and principles for securities regulation, including disclosure standards and cooperation between securities authorities (chunk_id f173909614befd49::455::1a1a). The passages describe distinct regulatory domains—one specific to MiCA crypto-asset services and the other a general international framework for securities regulation—without indicating any specific obligation in one regime that conflicts with 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:edb20bc00fd39bdcc27a518b", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 234 Information Security"}, "regime_b": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "non_conflict_subtype": "aligned_complementary", "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"}, {"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."}, {"chunk_id": "38116fa7dc9c103e::457::f788", "source_doc": "CPG_234_Information_Security_PG.pdf", "page": 27, "passage": "Notifications\nInteraction between CPS 232 and CPS 234 notifications\nUnder CPS 234, an APRA-regulated entity must notify APRA of information security\nincidents that meet specified criteria. Prudential Standard CPS 232 Business Continuity\nManagement also includes a requirement for notifying APRA of disruptions that meet\nspecified criteria. Where a disruption resulting from an information security incident\nmeets the criteria for notifying APRA under CPS 232, an APRA-regulated entity must\nnotify APRA in accordance with the CPS 232 requirements. Under these circumstances,\nthe notification under CPS 232 would be taken to also be a notification under CPS 234. CPS 234 notifications\nUnder CPS 234, an APRA-regulated entity is required to notify APRA of information\nsecurity incidents and information security control weaknesses as soon as possible and\nno later than the timeframes prescribed. For this purpose, APRA expects a regulated\nentity would notify APRA as soon as possible of such an incident or control weakness,\neven in the absence of complete information as to the incident and the intended\nresponse."}], "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": "APRA's Prudential Standard CPS 234 imposes an information-security capability, incident-notification and third-party-management regime on APRA-regulated entities. DORA establishes a substantively parallel ICT risk-management, incident-reporting and third-party risk regime on EU financial entities. They share architecture (governance accountability, board oversight, third-party controls, incident notification) but apply to non-overlapping regulated populations and use different reporting channels and thresholds. A single firm with operations in both jurisdictions must comply with both, but the obligations do not pull against each other; rather, DORA tends to be the strict-set and CPS 234 compliance is largely subsumed by mature DORA controls. This is a candidate for the equivalences corpus.", "would_conflict_if": ["Reporting timelines were strictly incompatible (e.g. APRA requires same-day notification for a class of incident that DORA forbids reporting until classified) — current text shows no such collision."]}
{"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:f33f82ec8a5e160ab865e77d", "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_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU AML/CTF Act + Rules"}, "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": "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): APRA CPS 230 operational-risk management standard and Australian AML/CTF Act + Rules (binding instruments) operate in disjoint regulatory domains at the obligation level. Operational risk management vs AML/CTF statutory obligations — 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": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:bdc7a155c2cc6b4e4de25f51", "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_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_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": "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": "AU_FEDREG_AML (Australia's AML/CTF Act and Rules — AUSTRAC framework) and SG_MAS_AML_GENERAL (MAS AML/CFT supervisory framework). Both jurisdictions implement comparable AML/CFT obligations consistent with FATF standards. Reinforcing rather than conflicting."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:09:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:6bb3c71af163c2d244ac81c2", "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_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "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": "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_AML_CTF regime focuses on anti-money laundering and counter-terrorism financing obligations, specifically requiring reporting entities to report suspicious matters, threshold transactions, and international funds transfer instructions to AUSTRAC (chunk 254ca2d92d196180::2ac::a5fe). The EU_DAC8 regime focuses on tax transparency and the automatic exchange of information regarding crypto-assets and their users (chunk c0300673081f7232::320::7b46). The obligations in the AU regime are regulatory compliance and financial crime prevention, whereas the obligations in the EU regime are tax reporting and administrative cooperation. The two regimes regulate distinct domains—financial crime compliance versus tax administration—and do not impose conflicting obligations on the same activity."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:44:26Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:c1e4660233570e8f36fd3f78", "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": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"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": "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_REVERSE_SOLICITATION regime regulates the authorization requirements and solicitation activities of third-country crypto-asset service providers (CASPs) within the EU (e.g., chunk 25cbbd878a1b21d3::298::6f7d). The MAS_TRM regime, as evidenced by chunk 20d526d712753652::401::f956, focuses on the application of principles-based guidelines (TRM Guidelines) and Fit and Proper criteria to licensees in Singapore. The passages describe distinct regulatory frameworks governing different jurisdictions and financial sectors (crypto-asset services vs. general financial institution licensing and conduct), with no evidence of overlapping obligations or conflicting requirements between the two."}
{"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:6265dc65f6afeb7c17c3d756", "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_EMD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EMD2"}, "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": "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 DAC 8 crypto-asset tax-reporting directive and EU EMD2 e-money-institution directive operate in disjoint regulatory domains at the obligation level. Crypto-tax reporting vs e-money institution authorisation — 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": "2026-06-15T16:12:43Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:36b5a7cde96a623581e26019", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "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": "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": "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_ATO_CRYPTO passages discuss the general tax treatment and adoption of crypto assets in Australia, including token mapping and compliance approaches (chunk_id e6bb47e92e88e16c::567::36c4). The EU_REVERSE_SOLICITATION passages specifically address the regulatory treatment of third-country crypto-asset service providers and the 'reverse solicitation' exemption under MiCA, focusing on client initiative and marketing activities (chunk_id 25cbbd878a1b21d3::4f8::561c). The obligations in the EU regime regarding client initiative and marketing do not impose a specific tax reporting or compliance burden that contradicts the general Australian tax framework described in the AU passages. Therefore, the regimes regulate different aspects of the crypto ecosystem and do not conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:462185195a55b6706e39a9f1", "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_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "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": "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": "AU_TRAVEL_RULE (AUSTRAC travel-rule consultation and AML/CTF obligations on DCE providers — AU is implementing FATF travel-rule standards) and INT_FATF_VASP (FATF VASP standards including R16 travel rule). AU is moving to implement FATF VASP guidance via the AML/CTF framework. Aligned direction."}
{"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:72bf0da18f82778c4f2c563e", "label": "conflict", "regime_a": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "FATF", "short_name": "INT_FATF_VASP"}, "regime_b": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "evidence_a": [{"chunk_id": "85240528438654b9::3f5::702b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 6, "passage": "1 This Guidance also updates the 2015 FATF Guidance for a Risk-Based Approach to Virtual\nCurrencies. UPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS  5\nThe Guidance details the full range of obligations applicable to VASPs as well as to VAs\nunder the FATF Recommendations, following a Recommendation-by-\nRecommendation approach. This includes clarifying that all of the funds or value-\nbased terms in the FATF Recommendations (e.g., \"property,\" \"proceeds,\" \"funds,\"\n\"funds or other assets,\" and other \"corresponding value\") include VAs. Consequently,\ncountries should apply all of the relevant measures under the FATF\nRecommendations to VAs, VA activities, and VASPs. The Guidance explains the VASP registration or licensing requirements, in particular\nhow to determine in which country/ies VASPs should be registered or licensed - at a\nminimum where they were created; or in the jurisdiction where their business is\nlocated in cases where they are a natural person."}, {"chunk_id": "dcbee7ab24bd0df2::478::fba7", "source_doc": "Guidance-Risk-Based-Supervision.pdf.coredownload.inline.pdf", "page": null, "passage": "Introducing a risk-based approach to supervision of DNFBPs 87\n8.3. Co-ordination and information sharing 90\n9. Supervision of VASPs 92\n9.1. Identifying the VASP population 92\n9.2. Identification of risk in the VASP sector 92\n9.3. VASP sector outreach and guidance 94\n9.4. Use of technology in VASP supervision 94\n9.5. Recruitment and training of VASP supervisors 95\n9.6. Multi-jurisdictional operations and supervisory co-operation on VASPs 95\n10. Supervision in the COVID-19 context 97\n10.1. Risk-based flexibility for reporting entities and clear communication of expectations and\nprovision of Guidance 97\nGlossary 98 4  GUIDANCE ON RISK-BASED SUPERVISION\nAcronyms\nAML/CFT Anti-money Laundering/Countering the Financing of Terrorism\nDNFBF Designated Non-financial Businesses and Professions\nFATF Financial Action Taskforce\nFI Financial Institution\nFIU Financial Intelligence Unit\nMI Management Information\nML Money Laundering\nMVTS Money Value Transfer Service\nRPA Robotic Process Automation\nSRA Supervisory Risk Assessments\nSRB Self-Regulatory Body\nTF Terrorist Financing\nTCSP Trust and Company Providers\nVASP Virtual Asset Service Providers"}], "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."}, {"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)."}], "rationale": "INT_FATF_VASP (FATF VASP definition for AML/CFT purposes) and AU_ASIC_CRYPTO (ASIC INFO 225 — when crypto activity is a 'financial service' requiring AFSL). Both classify the same crypto-asset activity but for different purposes, and the classifications turn on FACTS about the service that may yield divergent results (FATF VASP yes, AU financial-product no — or vice versa). The downstream obligations differ; resolution requires fact-specific analysis.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:29Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-16T05:15:44Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:646c34d5817f01f9a3fd5171", "label": "conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "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": "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": "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": "AU_ASIC_AFSL (Australian Financial Services Licence — KYC, recordkeeping, and client-disclosure obligations on AFS licensees) and EU_GDPR (cross-border data transfer principles under Article 44+). When AU AFS licensees serve EU-resident clients, the AFSL-mandated KYC and recordkeeping generates personal-data flows from EU to AU; GDPR Chapter V cross-border transfer restrictions engage. Operationally resolvable via GDPR Article 6(1)(c) (legal-obligation lawful basis) plus Chapter V mechanisms (SCCs or Art. 49 derogations). Same conflict shape as the labelled EU TFR ↔ EU GDPR conflict, applied to AU AFSL framework.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:33Z", "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:57ca1903af12013cc4e43059", "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_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU Treasury DAP"}, "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": "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 234 information security standard and AU Treasury Digital Asset Platforms framework operate in disjoint regulatory domains at the obligation level. Info-sec standard vs DAP-framework proposal — different statutory 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": "2026-06-15T17:07:03Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:8183d63f6119590d12308525", "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_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "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": "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 AU_TRAVEL_RULE passages discuss the registration of remittance network providers and virtual asset service providers (DCEs) under Australian law, and note that Australia is consulting on extending the FATF 'Travel Rule' to digital currency transactions (chunk_ids c4a92930a8caf822::380::0a18, cf7cefacba3f94bc::383::7d9d). The EU_MICA_TITLE_V_CASP passages focus on the application for authorisation as a Crypto-Asset Service Provider (CASP) under the Markets in Crypto-Assets Regulation (MiCA), including the information requirements for applications and the establishment of a public register (chunk_ids c51ad46265cea4e5::147::6214, c51ad46265cea4e5::340::9399). The obligations in the EU regime regarding authorisation and registration do not conflict with the Australian regime's focus on remittance sector registration and the potential future implementation of the Travel Rule. The regimes regulate different aspects of the crypto-asset ecosystem (authorisation vs. remittance registration/travel rule consultation) and do not impose mutually exclusive 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:862994da6164461b63372472", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DAC 8"}, "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": "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::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": "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": "DAC8 is the EU crypto-asset tax-reporting directive imposing due-diligence and reporting obligations on Reporting Crypto-Asset Service Providers. MiFID II is the investment-firm conduct regime. The two directives operate in disjoint domains — tax reporting vs investment conduct. No obligation in one pushes against any obligation in the other.", "would_conflict_if": ["A future MiFID amendment classified crypto-assets as financial instruments and DAC8 reporting overlapped with MiFID II transaction reporting — possible but speculative."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:23:02Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:dd31e22b3301553bb78c5596", "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_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "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": "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 APRA CPS234 (chunk 4b6fab404e7acfca::3c4::1564) establishes that it is a Prudential Practice Guide regarding Operational Risk Management and Information Security for APRA-regulated entities. The evidence for EU MiCA Title V CASP (chunk c51ad46265cea4e5::147::6214) outlines the requirements for authorisation as a Crypto-Asset Service Provider (CASP) under the Markets in Crypto-Assets Regulation. The two regimes regulate distinct domains: APRA CPS234 governs prudential risk management for traditional financial institutions, while MiCA Title V CASP governs the licensing and conduct of crypto-asset service providers. There is no specific obligation in one regime that conflicts with a specific obligation in the other."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:52:40Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:b7e29fcea7ea4e756aaade10", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "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": "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": "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": "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) (chunk_ids e9f6b0a9e797777d::5d6::e5ff, e9f6b0a9e797777d::4ba::1af3). The SG_PSA_DPT regime regulates Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) obligations for Digital Payment Token (DPT) service providers under the Payment Services Act (chunk_ids 4b4c3c417dc293ba::185::f41d, 018117ef1e757630::4b5::9ef5). The obligations are distinct: one focuses on data protection and privacy standards for cross-border data flows, while the other focuses on financial crime prevention and licensing for digital asset services. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other; they regulate different domains of compliance."}
{"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:8f4e549ef3636f98d8ee7c53", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "regime_b": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "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."}, {"chunk_id": "3a1785f95cb37b3c::5a9::fa3c", "source_doc": "AMLA_Regulation_EU_2024-1620.pdf", "page": 43, "passage": "Article 29\nLanguage arrangements in direct supervision\n1. The Authority and the financial supervisors shall adopt arrangements for their communications within the AML/CFT\nsupervisory system, including the language(s) to be used.\n2. Any document which a selected obliged entity or any other natural or legal person individually subject to the\nAuthority's supervisory procedures submits to the Authority may be drafted in any of the official languages of the Union,\nchosen by the selected obliged entity or natural or legal person concerned.\n3. The Authority, the selected obliged entities and any other legal or natural person individually subject to the\nAuthority's supervisory procedures may agree to exclusively use one of the official languages of the Union in their written\ncommunications, including with regard to the Authority's supervisory decisions.\n4. Where an agreement on the exclusive use of one language as referred to in paragraph 3 is subsequently revoked, that\nrevocation shall only affect the aspects of the Authority's supervisory procedure which have not yet been carried out.\n5. Where participants in an oral hearing request to be heard in an official language of the Union other than the language\nof the Authority's supervisory procedure, sufficient advance notice of that requirement shall be given to the Authority so\nthat it can make the necessary arrangements.\nSECTION 4\nIndirect supervision of non-selected obliged entities"}], "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)."}, {"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."}], "rationale": "AMLA (Reg 2024/1620) and AMLD6 (Dir 2024/1640) are the two supervisory pieces of the EU AML package: AMLA establishes the new EU-level supervisor, AMLD6 sets out the Member-State supervisory architecture and predicate-offence framework. They allocate supervisory responsibility between EU and Member-State levels without overlap or contradiction. Hard negative — both regulations were drafted in tandem to dovetail.", "would_conflict_if": ["AMLA's direct-supervision powers extended into Member-State conduct that AMLD6 reserves to national authorities — Art 13 of AMLA explicitly carves the perimeter."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:35:43Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:30521ed994ea0cf25b32adeb", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLD6"}, "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)."}], "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 AMLD6 passage (chunk 85307f9e2a040982::14a::134d) discusses the scope of the Directive, specifically mentioning the inclusion of 'digital operational resilience for the financial sector' and referencing other financial directives. The INT_BASEL_CRYPTO passage (chunk 32afd37cade34f84::3a4::1a5b) defines 'bank exposure' for capital requirements, focusing on claims on licensed financial institutions and prudential standards. The obligations in the Basel text regarding capital adequacy and risk weighting do not impose a specific, conflicting obligation on the entity or transaction type that is regulated by the AMLD6 passage. The regimes regulate distinct aspects of financial stability—AML compliance and operational resilience versus capital adequacy—resulting in no direct conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:38:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:e1933b9214e93534bc60b56c", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "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": "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": "abc2247bc6415d1d::45c::8031", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": null, "passage": "IRAS e-Tax Guide\n(Third Edition) Published by\nInland Revenue Authority of Singapore\nPublished on 30 Jan 2026\nFirst edition on 19 Nov 2019\nSecond edition on 3 Aug 2022\nDisclaimers: IRAS shall not be responsible or held accountable in any way for any damage, loss or expense\nwhatsoever, arising directly or indirectly from any inaccuracy or incompleteness in the Contents of this e-Tax\nGuide, or errors or omissions in the transmission of the Contents. IRAS shall not be responsible or held\naccountable in any way for any decision made or action taken by you or any third party in reliance upon the\nContents in this e-Tax Guide. Except where specific contents carry legal force, this information aims to provide\na better general understanding of taxpayers' tax obligations and is not intended to comprehensively address\nall possible tax issues that may arise. While every effort has been made to ensure that this information is\nconsistent with existing law and practice, should there be any changes, IRAS reserves the right to vary its\nposition accordingly.\n© Inland Revenue Authority of Singapore\nAll rights reserved."}, {"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 EU MIFID2 passages regulate the conduct of investment firms, focusing on product governance, suitability assessments, and client communication standards (e.g., chunk_ids 28dfda0f6a6539b6::620::92ed, 28dfda0f6a6539b6::502::1957). The SG IRAS TAX passages regulate tax obligations, specifically regarding the Goods and Services Tax (GST) treatment of digital payment tokens and record-keeping requirements (e.g., chunk_ids abc2247bc6415d1d::41e::b184, 7c5602f8b898a7ab::277::e4ae). The obligations in MIFID2 relate to the provision of investment services and the suitability of financial instruments, while the obligations in IRAS relate to the tax treatment of digital assets. These are distinct regulatory domains; the conduct requirements of MIFID2 do not impose a tax liability or record-keeping standard that conflicts with the GST treatment outlined in the IRAS passages. Therefore, the regimes are non-conflicting."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:29:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:070c71c8ef5c88abcc636df4", "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_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_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": "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 for AU_APRA_CPS230 focuses on operational risk management, business continuity, and service provider management for APRA-regulated entities. The evidence for INT_IOSCO_GENERAL discusses the IOSCO Principles, methodology for disclosure standards, and general regulatory objectives. The obligations in CPS 230 (e.g., maintaining critical operations through disruptions) are specific to prudential supervision and operational resilience, whereas the IOSCO passages address securities regulation, disclosure standards, and cross-border offerings. There is no specific obligation in IOSCO that creates a conflict with the operational risk management requirements of CPS 230. Therefore, the regimes regulate different domains."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:06:58Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:2bdffdad098a110eec19f744", "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_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_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."}, {"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::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_REVERSE_SOLICITATION regime regulates the authorization and solicitation of crypto-asset services by third-country firms within the EU (chunk_ids 25cbbd878a1b21d3::4f8::561c, 25cbbd878a1b21d3::298::6f7d). In contrast, the INT_BASEL_GENERAL regime addresses banking capital adequacy, specifically the leverage ratio, general provisions, and expected losses (chunk_id 32afd37cade34f84::34b::8d30). The obligations in Regime A relate to marketing and client acquisition for crypto-assets, while Regime B concerns financial reporting and capital calculations for banks. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B; the regimes regulate distinct domains of financial activity."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:43:07Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:d9542bf1d90acc8d12e01626", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "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": "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": "c0300673081f7232::373::b8ed", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(10) Directive 2011/16/EU lays down obligations for financial institutions to report financial account information to tax\nadministrations that are then required to exchange that information with other relevant Member States. However,\nmost crypto-assets are not obliged to be reported under that Directive because they do not constitute money held in\ndepository accounts nor in financial assets. In addition, crypto-asset service providers as well as crypto-asset\noperators are in most cases not covered by the current definition of financial institution under\nDirective 2011/16/EU.\n\n(11) In order to address new challenges arising from the growing use of alternative means of payment and investment,\nwhich pose new risks of tax evasion and are not yet covered by Directive 2011/16/EU, the rules on the reporting\nand exchange of information should cover crypto-assets and their users."}], "rationale": "The regimes regulate distinct domains. APRA CPS234 (and CPG 234) focuses on prudential operational risk management and information security for APRA-regulated entities. In contrast, EU DAC8 is a tax directive governing the automatic exchange of information regarding crypto-asset users. The evidence confirms that DAC8 addresses tax reporting obligations for crypto-asset service providers, which is a separate regulatory objective from the prudential risk management obligations outlined in APRA's guidance. Therefore, there is no overlap of obligations between the two regimes."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:53:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:7a2accdfc3128df6076cd995", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_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": "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"}], "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": "The Basel III framework (Regime A) regulates banking capital adequacy, leverage ratios, and credit risk provisions (e.g., fiduciary assets, general provisions) [32afd37cade34f84::34b::8d30, 32afd37cade34f84::34e::4d5c]. The Singapore Personal Data Protection Act (PDPA) (Regime B) governs the collection, use, and disclosure of personal data, including requirements for consent and notification [0e996ae99839f19e::37b::85a8, 0e996ae99839f19e::61d::14e5]. The obligations in Regime A relate to financial risk management and accounting, while the obligations in Regime B relate to data privacy and consumer protection. There is no specific obligation in the Basel framework that conflicts with the specific obligations in the PDPA; they regulate distinct domains of banking operations."}
{"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:f8afa3cc7dab4e95335c1a32", "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_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU Privacy"}, "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": "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": "Bulk Tier-1 label (claude_sme_v1_bulk): ASIC's crypto-asset INFO 225 / RG 282 guidance and Australian Privacy Act + APPs operate in disjoint regulatory domains at the obligation level. ASIC crypto guidance vs Privacy Act — 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": "2026-06-15T15:33:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:6eff2b626c80b978a7dae907", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "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": "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": "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_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 secretarial responsibilities (chunk 0fc4f857c226f510::375::66b5). The evidence from Regime B (SG_FOUNDATIONAL_LEGISLATION) discusses MAS enforcement actions against ICO issuers and exchanges, and the intention to expand legislation to align with international AML/CFT requirements (chunk b49627bb889ef1d9::3ef::7168). The obligations in Regime A relate to corporate governance and internal company operations, while the obligations in Regime B relate to financial services regulation and enforcement against digital token offerings. These are distinct regulatory domains with no apparent 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:0e70c3a936cb2a7d15be0858", "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_NIS2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "NIS 2"}, "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": "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."}, {"chunk_id": "20d29e9c5300ae10::581::f93d", "source_doc": "NIS2_Directive_EU_2022-2555.pdf", "page": 6, "passage": "(24) Where provisions of a sector-specific Union legal act require essential or important entities to comply with reporting\nobligations that are at least equivalent in effect to the reporting obligations laid down in this Directive, the\nconsistency and effectiveness of the handling of incident notifications should be ensured. To that end, the\nprovisions relating to incident notifications of the sector-specific Union legal act should provide the CSIRTs, the\ncompetent authorities or the single points of contact on cybersecurity (single points of contact) under this Directive\nwith an immediate access to the incident notifications submitted in accordance with the sector-specific Union legal\nact. In particular, such immediate access can be ensured if incident notifications are being forwarded without undue\ndelay to the CSIRT, the competent authority or the single point of contact under this Directive. Where appropriate,\nMember States should put in place an automatic and direct reporting mechanism that ensures systematic and\nimmediate sharing of information with the CSIRTs, the competent authorities or the single points of contact\nconcerning the handling of such incident notifications. For the purpose of simplifying reporting and of\nimplementing the automatic and direct reporting mechanism, Member States could, in accordance with the sector-\nspecific Union legal act, use a single entry point."}], "rationale": "AMLR/TFR is the EU AML/CFT instrument set imposing customer due diligence and travel-rule transmission. NIS2 is the horizontal cybersecurity directive for essential and important entities. The two directives operate in disjoint domains, and NIS2 Recital 24 contains an explicit lex specialis clause for sector-specific Union legal acts with equivalent reporting obligations — DORA fills that role for EU financial entities. No AMLR/TFR obligation pushes against any NIS2 obligation.", "would_conflict_if": ["NIS2 incident-notification timing forced disclosure of an AML SMR that AMLR confidentiality (tipping-off prohibition) rules forbade — designed to be cumulative with separate channels."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:08:45Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:20c76a88eb7b27c883c7e366", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "regime_b": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "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": "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_CORPS Act passage (chunk 0fc4f857c226f510::375::66b5) outlines the interaction between the Act and the Australian Charities and Not-for-profits Commission Act, detailing specific provisions regarding company duties and director responsibilities. The EU_AMLA passage (chunk df546f2364aaf9e2::25a::6ab3) establishes the legal framework for anti-money laundering and countering the financing of terrorism (AML/CFT) obligations and the institutional framework for the Authority for anti-money laundering and countering the financing of terrorism (AMLA). The obligations described in the AU passage relate to corporate governance and director duties, while the obligations in the EU passage relate to AML/CFT compliance and supervisory cooperation. These are distinct regulatory domains with no apparent overlap of obligations."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:23:39Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:e0920dee5298e3bc98acf2ae", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DORA"}, "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": "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"}], "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": "The obligations in EU_DORA focus on the security of network and information systems, digital operational resilience, and ICT risk management for financial entities (chunk_ids 85307f9e2a040982::4c8::ae53, 85307f9e2a040982::3d7::f935). In contrast, the obligations in SG_PSA_DPT relate to the licensing of Digital Payment Token (DPT) service providers and their Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) controls (chunk_ids 4b4c3c417dc293ba::185::f41d, 018117ef1e757630::4b5::9ef5). The regimes regulate distinct aspects of the financial ecosystem—operational resilience and ICT security versus licensing and AML/CFT compliance for DPT services—and do not impose conflicting obligations on the same specific activity."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:44:41Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:4197a37a2370ba661b3d3a8f", "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", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "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": "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 AU_FEDREG_AML passages describe obligations for reporting entities under the AML/CTF Act, including customer identification, suspicious transaction reporting, and program requirements (chunk cf7cefacba3f94bc::49a::f39e). The EU_MICA passages describe a legal framework for crypto-asset services, including the provision of advice on crypto-assets and the authorisation of crypto-asset service providers (chunk f9082873c5d9ba9d::302::bbe0). The obligations in the AML regime relate to financial crime prevention and customer due diligence, while the MiCA regime relates to the licensing and conduct of crypto-asset service providers. The passages do not describe conflicting obligations or overlapping scopes; they regulate distinct domains of financial activity."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.82, "record_type": "conflict", "pair_id": "conflict:d4ba81ba75743bc91610cc2e", "label": "conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "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": "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": "AU_PRIVACY (APP 8 cross-border disclosure restrictions) and INT_FATF_VASP (FATF VASP guidance — AML/CFT standards requiring customer identification and cross-border information sharing). FATF VASP implementations require sharing personal data of senders/recipients; APP 8 restricts overseas disclosure. Operationally resolvable via APP 6.2(b) (required by law) when AU implements FATF via AML/CTF for VASP-equivalent entities. Same cross-jurisdictional AML-privacy shape.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:03Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:28:52Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:2011b553eb7f937f3aacf405", "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_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "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": "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 evidence from APRA CPS 230 focuses on operational resilience, business continuity, and the management of service providers to ensure an entity can meet its prudential obligations during disruptions (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c). In contrast, the SG IRAS Tax evidence addresses the Goods and Services Tax (GST) treatment of digital payment tokens, specifically that such tokens are exempt supplies and businesses trading in them are no longer liable for GST registration (chunk_ids abc2247bc6415d1d::41e::b184, abc2247bc6415d1d::5c7::68f5). The obligations in the Australian prudential standard regarding operational risk management do not impose conflicting requirements on the GST treatment or registration status of digital payment tokens under Singaporean tax law. The regimes regulate distinct domains: prudential resilience and tax compliance."}
{"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:54cb5aa3bf38ab36c7ddc2b1", "label": "conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "conflict_type": "recurring_friction", "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)."}, {"chunk_id": "abc9007e907ef318::512::fba2", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "Content of the proposed updates\n12 The proposed changes to draft updated INFO 225 include:\n(a) adding guidance on a facility for making a financial investment (s763B\nof the Corporations Act);\n(b) decreasing the focus on the role of initial coin offerings, as this is only\none method for selling digital assets to consumers;\n(c) adding further discussion of the typical financial services that we expect\nan entity would apply for when applying for or applying to vary an\nAustralian financial services (AFS) licence, and noting the application\nprocess;\n(d) including 13 worked examples to outline how ASIC interprets the\nexisting financial product definitions applied to hypothetical scenarios;\n(e) extending the good practice guidance directed to responsible entities in\nINFO 225 to also apply to providers of custodial and depository\nservices;\n(f) adding a section to address applications for relief and granting no-action\nletters;\n(g) adding consideration of the design and distribution obligations; and\n(h) edits to consolidate concepts, improve flow and provide further details\nand clarifications, where appropriate.\n13 The current version of INFO 225 is titled 'Crypto-assets'. We propose as\npart of this update to change the title of INFO 225 to 'Digital assets', and use\nthis term throughout."}], "evidence_b": [{"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."}], "rationale": "AU_ATO_CRYPTO (ATO crypto-asset tax framework — every disposal is a CGT event) and AU_ASIC_CRYPTO (ASIC AFSL/INFO 225 framework — operational obligations on entities providing crypto-asset services). The friction is ongoing: every transaction on an AU crypto-asset platform generates both a CGT event (taxpayer obligation, platform-side recordkeeping) and AFSL operational obligations (record-keeping, reporting, suitability documentation for facility access). Neither regime causes the other's friction, but the combination scales with transaction count — design choice for crypto regulation in AU creates a recurring cost both parties bear.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:25Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:36:25Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:649b5e5ed622abbca86322d7", "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_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "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": "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": "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": "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 passages for SG_MAS_AML_GENERAL discuss AML/CFT obligations, specifically the licensing of Digital Payment Token (DPT) service providers and the supervision of money laundering risks (chunk_ids 321e082bdbe732d3::309::b080, b49627bb889ef1d9::1b6::0802). The passages for SG_MAS_PRUDENTIAL_CRYPTO discuss prudential treatment and capital requirements for cryptoasset exposures and stablecoin issuers (chunk_ids 321e082bdbe732d3::309::b080, 7c04f2a0bd85290a::449::02f2). While both regimes apply to entities in the digital asset space, the specific obligations—AML/CFT compliance versus prudential capital and risk management—are distinct and do not create a direct conflict. The regimes regulate different aspects of the digital asset ecosystem."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:37:45Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:12e3b0ce645aa5fdf522abb7", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "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": "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": "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_NIS2 passage discusses the preparation of technical standards and guidelines for access controls and cryptography under the NIS2 Directive (chunk_id 3c9eb3a25c93f394::474::4786). The SG_PSA_DPT passage applies to holders of a payment service licence providing digital payment token services under the Payment Services Act 2019 (chunk_id 4b4c3c417dc293ba::185::f41d). The obligations regarding ICT security and access controls under NIS2 are distinct from the AML/CFT licensing and operational requirements for DPT service providers under Singapore's MAS Notice PSN02. The regimes regulate different domains (ICT security vs. financial services licensing and AML/CFT), 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": "2026-06-15T15:47:09Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:93e60b81f1fedf73242c856f", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "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": "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": "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 from the Australian Corporations Act passage (chunk 0fc4f857c226f510::375::66b5) outlines general corporate governance duties and interactions with the Australian Charities and Not-for-profits Commission Act, such as director duties and constitutional requirements. The evidence from the Singapore Stablecoin passage (chunk 58f45cd2ef3de201::36c::e2f6) describes the scope of MAS's stablecoin regulatory regime, specifically focusing on Single-Currency Stablecoins (SCS) and their distinction from Digital Payment Tokens. The two regimes regulate distinct domains: the Australian regime governs corporate governance and director responsibilities, while the Singapore regime governs the issuance and regulation of specific digital assets (stablecoins). There is no evidence of a specific obligation in the Australian Corporations Act that conflicts with a specific obligation in the Singapore Stablecoin regime. Therefore, the regimes are non-conflicting."}
{"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:1ba521c0cdb953f4b849cd0d", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_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": "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": "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": "EU_GDPR (cross-border data transfer principles) and SG_PSA_GENERAL (Singapore Payment Services Act licensing framework including AML/CFT and customer-due-diligence obligations on PSA licensees). When SG PSA-licensed entities serve EU-resident clients, the PSA-mandated customer data collection and transmission to MAS or counterparty CASPs engages GDPR cross-border transfer restrictions on the EU side. Operationally resolvable via GDPR Article 6(1)(c) + Chapter V mechanisms. Same conflict shape as EU TFR ↔ EU GDPR.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:38Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T17:30:41Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:da809b1b683eeea0ba552689", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_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": "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": "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 passages (chunk_id fe52dd87e13dba41::261::59a4) provide general guidance on risk assessment and the complementary nature of financial inclusion and AML/CFT objectives. The SG Stablecoin passages (chunk_id 58f45cd2ef3de201::36c::e2f6) describe the scope of Singapore's MAS stablecoin framework, specifically that non-SCS will continue to be subject to the existing DPT regulatory regime. The regimes regulate different domains: FATF provides international standards for AML/CFT risk assessment, while the SG Stablecoin regime defines the specific regulatory perimeter for stablecoin issuance in Singapore. There is no specific obligation in the FATF passages that pushes against a specific obligation in the SG Stablecoin passages."}
{"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:62aad638bdc948241bb34adc", "label": "conflict", "regime_a": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU_FEDREG_AML"}, "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": "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": "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_FEDREG_AML (Australian AML/CTF Act and Rules — AUSTRAC reporting obligations requiring KYC data collection and cross-border transfer reporting) and SG_PDPA (Singapore Personal Data Protection Act restricting collection and disclosure of personal data without consent or statutory authorisation). When AU reporting entities have SG-resident customers and report their data to AUSTRAC or to SG counterparties, PDPA's restrictions engage. Operationally resolvable via PDPA s.13(b) (required or authorised by law) carve-out. Same conflict shape as the labelled AU AML/CTF ↔ AU PRIVACY conflict in the careful cohort, scaled to SG-cross-jurisdictional framing.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:51Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:e16d2a236b551347f2d7c51f", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "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": "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": "AU_ASIC_AFSL (Australian Financial Services Licence framework — proposed digital-asset-facility licensing) and EU_MIFID2 (EU Markets in Financial Instruments Directive — investment-firm conduct of business and product governance). Both regulate financial-services entities in their jurisdictions but with materially different mechanisms — AU AFSL is general entity-licensing; EU MiFID2 is investment-firm-specific conduct. Distinct jurisdictional perimeters; no direct conflict on cited passages."}
{"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:a425c3e5f90597aef05d8c6f", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "Privacy Act + APP Guidelines"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"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": "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."}], "rationale": "The Privacy Act/APPs regulate handling of personal information by Australian APP entities. MiCA regulates crypto-asset market authorisation and conduct by EU CASPs. The two regimes apply to different regulated populations in different jurisdictions and address different subject matters. An Australian APP entity is not within MiCA's territorial scope unless it also operates as a CASP in the EU; in that case it complies with both independently. No obligation in one pushes against any obligation in the other.", "would_conflict_if": ["MiCA delegated regulation purported to override APP cross-border-disclosure rules for an Australian-based CASP (it does not and could not, given territorial scope)."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:14:10Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:7cf1d73a3acc274831cff8d7", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "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": "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": "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_NIS2 passage discusses the preparation of technical standards and guidelines for ICT security measures, specifically access controls and cryptography, within the context of the Network and Information Security Directive (NIS2) and the Critical Entities Regulation. In contrast, the SG_AML passage outlines mandatory training obligations for officers and employees regarding AML/CFT laws, suspicious transaction reporting, and internal policies. The obligations in the EU_NIS2 passage relate to technical ICT security measures, while the obligations in the SG_AML passage relate to financial crime prevention and staff training. These are distinct regulatory domains with no apparent overlap or conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.7, "record_type": "conflict", "pair_id": "conflict:cfd44392c1c385017cc067b4", "label": "conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "conflict_type": "interpretive_fact_sensitive", "severity": "low", "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": "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_TRAVEL_RULE (FATF travel rule for digital currency exchanges — AUSTRAC consultation; per the cited passage Australia has NOT YET implemented the travel rule for digital currency exchanges) and SG_PDPA (Singapore Personal Data Protection Act). When/if Australia implements the FATF travel rule, AU DCEs sending crypto value to SG counterparties would need to share originator/beneficiary personal data, engaging PDPA's collection/disclosure restrictions on the SG side. The conflict is currently latent (interpretive_fact_sensitive: depends on whether and how AU implements the travel rule, and whether the SG counterparty is a regulated DPT licensee with the 'required by law' carve-out). Low severity because the obligation is not in force and the resolution path (SG PDPA s.13(b) carve-out) is established.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:24:44Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "low", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:32:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:594fb1a9b73712eefd82e21b", "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_FOUNDATIONAL_LEGISLATION", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_FOUNDATIONAL_LEGISLATION"}, "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": "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 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) [491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e]. The Singapore foundational legislation passages discuss MAS enforcement actions against ICO issuers and exchanges, and the intention to align with international AML/CFT standards [b49627bb889ef1d9::3ef::7168, 7c04f2a0bd85290a::413::fc6a]. The obligations in the EU regime regarding white paper disclosure and liability do not directly oppose the enforcement or supervisory scope described in the Singapore passages. Instead, the Singapore text explicitly acknowledges the applicability of foreign regulations, such as the EU MiCA, and suggests that foreign SCS (Security Token Offerings) meeting equivalent standards may be recognized [7c04f2a0bd85290a::413::fc6a]. Therefore, the regimes regulate distinct aspects of the token ecosystem (disclosure standards vs. enforcement and supervisory scope) and do not conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:00:01Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:14128159b83d300f172dab58", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "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": "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": "d758cb6128239f36::429::2caa", "source_doc": "Virtual-Assets-Red-Flag-Indicators.pdf.coredownload.pdf", "page": null, "passage": "FATF REPORT\nVirtual Assets\nRed Flag Indicators\nof Money Laundering and\nTerrorist Financing\nSeptember 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:\nMoney Laundering and Terrorist Financing Red Flag Indicators Associated with Virtual Assets,\nFATF (2020),\nFATF, Paris, France,\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/Virtual-Assets-Red-Flag-Indicators.html\n© 2020 FATF/OECD."}], "rationale": "The EU_MAR regime regulates market integrity, specifically insider dealing and market manipulation (chunks 5cc4a27bc578287a::165::3333, 5cc4a27bc578287a::4ee::5950). The FATF_R16 regime regulates Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) standards, specifically regarding virtual assets and money transfer services (chunks 5d489619a0fb9ecf::377::a91e, d758cb6128239f36::429::2caa). The obligations in EU_MAR focus on preventing market abuse and detecting insider dealing, while FATF_R16 focuses on identifying customers and detecting money laundering/terrorist financing. These are distinct regulatory domains with no apparent overlap of obligations."}
{"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:9cccb99f6ba2f0bde901596c", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "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": "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": "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": "EU_NIS2 (EU Network and Information Security Directive — ICT access controls and security) and SG_MAS_OUTSOURCING (MAS's Outsourcing Guidelines — material outsourcing arrangements with third-party service providers). Both touch on third-party / ICT risk but address different specific concerns — NIS2 is broad cybersecurity for in-scope entities; MAS outsourcing focuses on supervision of outsourced business activities. Distinct mechanisms; no direct obligation conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:35:26Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:52365963cd4360de02e94351", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "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": "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": "d758cb6128239f36::429::2caa", "source_doc": "Virtual-Assets-Red-Flag-Indicators.pdf.coredownload.pdf", "page": null, "passage": "FATF REPORT\nVirtual Assets\nRed Flag Indicators\nof Money Laundering and\nTerrorist Financing\nSeptember 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:\nMoney Laundering and Terrorist Financing Red Flag Indicators Associated with Virtual Assets,\nFATF (2020),\nFATF, Paris, France,\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/Virtual-Assets-Red-Flag-Indicators.html\n© 2020 FATF/OECD."}], "rationale": "The Australian regime (AU_ASIC_CRYPTO) focuses on the licensing and classification of crypto-assets as financial products and services under the Corporations Act 2001. The FATF regime (FATF_R16) focuses on anti-money laundering and counter-terrorist financing (AML/CFT) obligations for Virtual Asset Service Providers (VASPs). The passages confirm that the FATF guidance addresses AML/CFT risks and red flags for virtual assets (chunk_id d758cb6128239f36::429::2caa), while the Australian guidance outlines the licensing framework for entities offering crypto products and services (chunk_id abc9007e907ef318::3c9::4151). These are distinct regulatory domains: one governs financial product licensing and consumer protection, while the other governs financial crime prevention. There is no evidence of a direct obligation in one regime that conflicts with a specific obligation in the other."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T17:06:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:d872b1e9e4ce1bf430f9e747", "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_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "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": "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."}], "rationale": "The AU_TRAVEL_RULE passages describe the registration and management of remittance networks and virtual asset service providers (chunk_ids c4a92930a8caf822::380::0a18, c4a92930a8caf822::57d::3f76). The EU_MIFID2 passages describe obligations for investment firms regarding product governance, suitability assessments, and client information (chunk_ids 28dfda0f6a6539b6::620::92ed, 28dfda0f6a6539b6::502::1957). The obligations in the AU regime relate to anti-money laundering/counter-terrorist financing (AML/CTF) registration and reporting, while the obligations in the EU regime relate to investment services and product governance. These are distinct regulatory domains with no apparent overlap of obligations."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.65, "record_type": "non_conflict", "pair_id": "non_conflict:262ed481b51df04acb312940", "label": "non_conflict", "regime_a": {"regime_id": "AU_PAYMENT_SYSTEMS", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_PAYMENT_SYSTEMS"}, "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": "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."}], "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_PAYMENT_SYSTEMS (PSRA 1998 — RBA powers over payment-system access and interoperability) and SG_PSA_DPT (MAS DPT licence AML notice under the PSA) both fall in the broad 'payments' topic but address different specific obligations. The A passage is about MAS authority to direct payment service providers on interoperability standards (note: appears to be SG content despite the AU prefix — possible weak retrieval). B is the MAS PSN02 AML notice for DPT licensees. No obligation tension visible on the cited passages."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:54:27Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:d4260f0285639835515216f0", "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_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_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": "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 (Regime A) regulates the solicitation of clients by third-country crypto-asset service providers, specifically prohibiting reverse solicitation where the firm solicits clients in the EU. The Singapore regime (Regime B) discusses the regulatory scope of the Monetary Authority of Singapore (MAS) regarding Security Token Offerings (SCS) and the adoption of a collegiate approach with regulators in other jurisdictions, including the recognition of foreign SCS issued under EU MiCA. The passages do not describe conflicting obligations; instead, they address distinct regulatory topics—client solicitation in the EU versus the recognition of foreign security tokens in Singapore. Therefore, the regimes are in different domains and do not conflict."}
{"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:0e67b88033186c6ca054dfec", "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_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "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": "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": "EU_AMLR_TFR (EU's AMLR + TFR — Regulation 2023/1113 and the broader EU AML framework) and INT_FATF_GENERAL (FATF's AML/CFT recommendations). The EU's AMLR/TFR is the EU's binding implementation of FATF AML standards including R16; the regimes are aligned by design."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:12:19Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:3873ce73c959d825aa5ca1c7", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "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": "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": "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": "The EU PSD2 passages focus on strong customer authentication (SCA) and security credentials for payment services (chunks adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b). The SG MAS passages discuss the prudential treatment of cryptoasset exposures, stablecoins, and the Payment Services Act (chunks 7c04f2a0bd85290a::46d::fd1b, 7c04f2a0bd85290a::449::02f2). The obligations in PSD2 regarding authentication and security credentials do not directly oppose the MAS prudential requirements for cryptoasset exposures or stablecoins. The regimes regulate distinct aspects of financial services—payment security versus cryptoasset prudential standards—resulting in no direct conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:32:53Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:2801f91608aafe3a13589fd7", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLD6"}, "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": "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": "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 AMLD6 passages discuss financial rules and operational resilience for the financial sector (chunk 85307f9e2a040982::14a::134d) and the financial rules applicable to the Authority (chunk 3a1785f95cb37b3c::34d::1756). The SG PSA_GENERAL passages discuss the scope of Payment Services Regulations, specifically regarding Digital Payment Token Services (DPT) and licensing (chunk 14cb9eb911d15322::42b::fe23), and the submission of comments on the regulatory scope of SCS (Secure Custody Services) (chunk 321e082bdbe732d3::309::b080). The obligations and topics in the EU passages (financial rules, resilience) do not overlap with the obligations and topics in the SG passages (payment services licensing, DPT scope). Therefore, the regimes regulate different domains 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:68fced56150f6b12e6ddb127", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "PSD2"}, "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": "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 AMLA Regulation establishing the AML supervisor and EU PSD2 payment-services directive are designed to coexist — obligations apply cumulatively without collision. PSPs are AMLR-obliged entities; AMLA supervises them via Article 13's direct-supervision perimeter — 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": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:2cb269bbe561ef4e6996ce31", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EMD2"}, "regime_b": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "PSD2"}, "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": "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."}, {"chunk_id": "adb1a81b9cecaf8c::778::03be", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 79, "passage": "Article 28(5) and Article 29(7) thereof, shall apply mutatis mutandis to such electronic money institution.\n5. Notwithstanding paragraph 4 of this Article, electronic money institutions shall not issue electronic money\nthrough agents. Electronic money institutions shall be allowed to provide payment services referred to in point (a)\nof Article 6(1) of this Directive through agents subject to the conditions laid down in Article 19 of Directive (EU)\n2015/2366.';\n(2) in Article 18, the following paragraph is added:\n'4. Member States shall allow electronic money institutions that have, before 13 January 2018, taken up activities\nin accordance with this Directive and with Directive 2007/64/EC in the Member State in which their head office is\nlocated to continue those activities in that Member State or in another Member State without being required to seek\nauthorisation in accordance with Article 3 of this Directive or to comply with other requirements laid down or\nreferred to in Title II of this Directive until 13 July 2018.\nMember States shall require electronic money institutions referred to in the first subparagraph to submit all relevant\ninformation to the competent authorities in order to allow the later to assess, by 13 July 2018, whether those\nelectronic money institutions comply with the requirements laid down in Title II of this Directive, and, if not, which\nmeasures need to be taken in order to ensure compliance or whether a withdrawal of authorisation is appropriate.\nElectronic money institutions referred to in the first subparagraph which upon verification by the competent\nauthorities comply with the requirements laid down in Title II shall be granted authorisation and shall be entered\nin the register. Where those electronic money institutions do not comply with the requirements laid down in Title II\nby 13 July 2018 they shall be prohibited from issuing electronic money.'."}], "rationale": "EMD2 (Directive 2009/110/EC) and PSD2 (Directive (EU) 2015/2366) are companion directives: EMD2 authorises and regulates electronic money institutions (EMIs), PSD2 authorises payment service providers (PSPs) more broadly. EMIs are specifically named in PSD2 as a class of PSP, with Article 28 cross-referencing EMD2 for agent-based distribution rules. The two directives are explicitly aligned — no obligation in one pushes against any obligation in the other. Hard negative.", "would_conflict_if": ["EMD2 Art 11 redemption rules required disclosures PSD2 confidentiality rules forbade — no such collision in current text."]}
{"annotator_id": 10116, "annotated_at": "2026-05-25T23:50:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:54c94c312423d62b189bed5b", "label": "conflict", "regime_a": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "PDPA"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "SG PSA DPT"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"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::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::4ae::c8f9", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 7, "passage": "13 Act 2012 2020Ed.\nby a data intermediary as if the personal data were processed by the\norganisation itself. (4) This Act does not apply in respect of -\n(a) personal data about an individual that is contained in a\nrecord that has been in existence for at least 100 years; or\n(b) personal data about a deceased individual, except that the\nprovisions relating to the disclosure of personal data and\nsection 24 (protection of personal data) apply in respect of\npersonal data about an individual who has been dead for\n10 years or less. (5) Except where business contact information is expressly\nmentioned, Parts 3, 4, 5, 6 and 6A do not apply to business contact\ninformation.\n[40/2020]\n(6) Unless otherwise expressly provided in this Act -\n(a) nothinginParts 3,4, 5, 6, 6Aand6Baffectsanyauthority,\nright, privilege or immunity conferred, or obligation or\nlimitation imposed, by or under the law, including legal\nprivilege, except that the performance of a contractual\nobligation is not an excuse for contravening this Act; and\n(b) theprovisionsofotherwrittenlawprevailtotheextentthat\nany provision of Parts 3, 4, 5, 6, 6A and 6B is inconsistent\nwith the provisions of that other written law.\n[40/2020]"}], "evidence_b": [{"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."}, {"chunk_id": "c8bd52de7a08b935::694::08db", "source_doc": "MAS_Notice_1014_MerchantBanks_2025-06-30.pdf", "page": 2, "passage": "\"payment service transaction\" means any transaction accepted, processed, or executed\nby the merchant bank in the course of carrying on its business of providing a specified\npayment service;\n\"personal data\" has the same meaning as defined in section 2(1) of the Personal Data\nProtection Act 2012;\n\"PS Act\" means the Payment Services Act 2019;\n\"reasonable measures\" means appropriate measures which are commensurate with the\nlevel of money laundering or terrorism financing risks;\n\"SFA\" means the Securities and Futures Act 2001;\n\"specified payment service\" means any of the following service:\n(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."}, {"chunk_id": "39886a6842407c92::7cf::c2ec", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 2, "passage": "2 In the case of a limited liability partnership or a limited partnership. Securities Regulation issued by the International Organisation of Securities\nCommissions, or the Insurance Core Principles issued by the International Association of\nInsurance Supervisors;\n\"cross-border wire transfer\" means a wire transfer where the ordering institution and the\nbeneficiary institution are located in different countries or jurisdictions and also refers to\nany chain of wire transfer in which at least one of the financial institutions involved is\nlocated in a different country or jurisdiction;\n\"custodian wallet service\" means the service of safekeeping and administration of digital\npayment tokens or instruments enabling control over digital payment tokens;\n\"customer\", in relation to a bank, means a person (whether a natural person, legal person\nor legal arrangement) -\n(a) with whom business relations are established or with whom the bank intends to\nestablish business relations; or\n(b) for whom the bank undertakes or intends to undertake any transaction without an\naccount being opened;\n[MAS Notice 626 (Amendment) 2025]\n\"digital CMP token\" means a digital representation of a capital markets product which can\nbe transferred, stored or traded electronically;\n\"digital payment token\" has the same meaning as defined in section 2(1) of the PS Act;\n\"digital payment token service\" has the same meaning as defined in section 2(1) of the\nPS Act;\n\"digital payment token transfer service\" means the service of accepting digital payment\ntoken from one digital payment token address or account, whether in Singapore or outside\nSingapore, as principal or agent, for the purposes of transferring, or arranging for the\ntransfer of, the digital payment token to another digital payment token address or account,\nwhether in Singapore or outside Singapore;\n\"digital token\" means -\n(a) a digital payment token; or\n(b) a digital CMP token;\n\"digital token transaction\" means -\n(a) a payment service transaction; or"}], "rationale": "MAS Notice PSN02 and the parallel MAS notices (626/824/1014) impose customer due diligence on DPT service providers, including collection of identifying information on customers and ongoing transaction monitoring. PDPA Part 4 imposes a consent baseline on the collection, use and disclosure of personal data, supplemented by Section 26 restricting cross-border transfer of personal data. The tension is operational: DPT service providers must collect customer personal data under PSN02-grade obligations while remaining within PDPA's consent architecture. Resolution: PDPA Part 4 Division 3 permits collection, use and disclosure without consent where required or authorised under written law — and MAS Notices issued under the PS Act / MAS Act / FSM Act are such law. For cross-border transmission, PDPA s 26's comparable-protection standard is met where the receiving institution is subject to equivalent AML/CFT obligations. The pair mirrors the previously-labelled `SG_AML :: SG_PDPA` operationally resolvable conflict and reaches the same conclusion at comparable severity.", "compliant_paths": ["Rely on the PDPA 'required or authorised by law' carve-out for collection/use/disclosure of CDD data under PSN02.", "For cross-border DPT-transfer information, evidence comparable-protection standard via the receiving institution's AML/CFT obligations or binding contractual clauses.", "When CDD data cannot be lawfully transmitted, refuse the wire transfer — itself the PDPA-compatible outcome under PSN02 paragraph 11.9 / 15.11."], "out_of_scope_assumptions": ["DPT service provider is MAS-licensed under the PS Act and captured by PSN02 or one of the parallel notices.", "Customer is a natural person under PDPA scope (entity-level CDD has a different overlay)."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:20:41Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:5d0400072e451d3ca4ae63f7", "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_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "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": "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 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 for applications. The SG MAS Outsourcing passages (a82833dc0f7ca903::5f1::735d) focus on the supervision of material outsourcing arrangements and the rights of MAS to access information from service providers. While both regimes involve supervision and information access, they regulate distinct obligations: MiCA regulates the licensing and registration of CASPs, whereas MAS regulates the conduct of outsourcing by financial institutions. There is no specific obligation in MiCA that conflicts with the specific outsourcing obligations in the MAS guidelines."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:04:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:dada4ff995ae36d8d7449d4d", "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_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_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": "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 EU_MIFID2 passages regulate the conduct of investment firms, focusing on product governance, suitability assessments, and client information disclosure (e.g., Article 24 and 25). In contrast, the INT_BASEL_GENERAL passages regulate banking capital adequacy, leverage ratios, and risk-weighted assets (e.g., Basel III framework). The obligations in MIFID2 regarding client suitability and product information do not impose conflicting requirements on the capital treatment or leverage ratio calculations described in the Basel passages. The regimes govern distinct operational domains—conduct of business versus prudential regulation—resulting in no friction between the specific obligations cited."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:01:40Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:cf097c6e3f7aa50d326cc98a", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "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": "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": "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_EMD2 passages discuss the 'digital operational resilience for the financial sector' and financial rules for the Authority, which are distinct from the operational conduct of Virtual Asset Service Providers (VASPs). The INT_FATF_VASP passages focus on the definition of VASPs, the FATF's technology-neutral approach to regulating the natural persons behind the technology, and the application of AML/CFT standards. There is no evidence in the provided passages of an obligation in EU_EMD2 that conflicts with an obligation in INT_FATF_VASP. The regimes regulate different domains (financial sector resilience vs. AML/CFT for VASPs)."}